NC State officials are disputing the NCAA's allegation that former Adidas consultant T.J. Gassnola gave $40,000 to a former Wolfpack assistant coach, who was supposed to help facilitate getting the money to star player Dennis Smith Jr.'s family in October 2015 to ensure he enrolled at the school.
In a 46-page response to the NCAA notice of allegations that the university received in July, NC State officials questioned whether there was evidence -- as laid out in last year's federal trial -- that Gassnola actually delivered $40,000 to former assistant coach Orlando Early, who was supposed to forward the money to Shawn Farmer, Smith's former trainer, who was then supposed to give the money to Smith's father.
"Specifically, the evidence in the record demonstrates that Smith Jr. did not receive any money and that he was unaware of any money being provided to Farmer and/or to his family by Adidas, Gassnola or Early," the response said.
The NCAA has alleged two Level I violations (the most serious) against the Wolfpack, including a failure to monitor charge against former coach Mark Gottfried, who has since been hired at Cal State Northridge.
"When this process started, we promised accountability where appropriate and vigorous defense where necessary, and our response does exactly that," NC State chancellor Randy Woodson said in a statement. "We look forward to a thorough and accurate review by the panel of the committee on infractions and a fair resolution of this case for the university and the NCAA."
The NCAA enforcement staff has 60 days to respond. The Wolfpack could appear in front of the NCAA's committee on infractions next spring.
The NCAA said Smith was ineligible while competing in 32 contests for the Wolfpack during the 2016-17 season, for which he was named ACC freshman of the year.
The allegations regarding Smith's recruitment were revealed in a federal indictment and criminal trial in New York last year. NC State acknowledged in its response that an agent first notified the university's general counsel in October 2017 that "Smith Jr.'s enrollment had been influenced by Adidas through Smith Jr.'s father, Dennis Smith Sr." NC State compliance officials interviewed the agent, but he declined to share additional details or the names of other individuals involved in the alleged scheme.
The general counsel relayed the information to the FBI's office in Raleigh, North Carolina, according to the response.
The Wolfpack also are accused of providing Smith a parking pass to an NC State football game before he enrolled in 2016, which is considered a Level II violation.
Early also is accused of providing 44 complimentary tickets to NC State men's basketball games to Farmer, as well as 106 complimentary tickets to Smith's family and friends.
In the response, NC State officials acknowledged that its former coaching staff ignored "well-established processes" and NCAA rules while distributing tickets to players' family and friends, and that corrective measures had since been implemented.
NC State is one of several schools under NCAA scrutiny as a result of the federal government's investigation of pay-for-play schemes in college basketball. Sources have told ESPN that the NCAA is actively investigating Arizona, Creighton, Kansas, Louisville, LSU and USC.
Gassnola testified during the October 2018 trial that he made two payments to people close to Smith, who spent 1½ seasons at NC State before becoming a lottery pick in the 2017 NBA draft. He currently is playing for the New York Knicks.
The first payment, of an unspecified amount, came during Smith's junior year of high school, after Andy Miller -- who ran the ASM Sports agency -- informed Gassnola that Smith wanted to leave the Adidas grassroots circuit.
NC State officials said athletic director Debbie Yow disassociated Miller and his agency from NC State for 10 years in September 2012 because of his conduct in an unrelated matter. According to the response, "Miller had not been truthful when NC State questioned him about his connection with an AAU coach (Desmond Eastman) who had been decertified by the NCAA."
The second alleged payment from Gassnola came in the fall of 2015, after Early reached out to Gassnola to say there were issues surrounding Smith, who had committed to NC State earlier in the fall.
There is evidence -- which came out in the trial -- that shows Gassnola withdrew $40,000 from a bank account and flew to Raleigh and rented a car in the fall of 2015.
"He was having issues with keeping that situation together," Gassnola told the jury.
Gassnola testified that he gave $40,000 in cash to Early. Early told Gassnola that he was going to give the money to Farmer. Gassnola said Adidas reimbursed him.
In the response, NC State officials argue that Adidas wasn't the source of the alleged $40,000 payment from Gassnola to Early. NC State alleges the money came from Martin Fox, a Texas-based middle man who is "affiliated with professional basketball player agents and business managers and who had no known relationship with Adidas."
Fox, a well-known Houston tennis coach, pleaded guilty to one felony charge in the college admissions scandal known as "Varsity Blues" on Nov. 15. Fox, 62, agreed to plead guilty to a racketeering conspiracy charge and is scheduled for sentencing on Feb. 14.
Prosecutors accused Fox of arranging bribes to get two students admitted to the University of San Diego as recruited athletes, and one to the University of Texas.
The NCAA has alleged that Adidas essentially acted as a booster of NC State and induced Smith to sign with the Wolfpack, which is sponsored by the apparel company. NC State argues that Fox is a third party with no affiliation to the school and provided the money for the alleged payment to steer Smith toward certain agents and financial advisers once he turned pro.
"Gassnola was acting on his own behalf or on behalf of Fox, an agent or business manager when Gassnola allegedly provided $40,000 to Early," the response said.
NC State officials also questioned Gassnola's credibility. Gassnola, a former youth basketball director from Springfield, Massachusetts, pleaded guilty in April 2018 to conspiracy to commit wire fraud for his role in pay-for-play schemes to steer recruits to Adidas-sponsored schools.
In September, he was sentenced to a one-year supervised release, including two months of home confinement and electronic monitoring, and a $100 fine, according to court records.
"Gassnola is an individual with a self-described 'degree in bull,' who has an extensive criminal history that includes assault, larceny, receipt of stolen property, tax evasion and habitual traffic offenses," the response said. "In short, Gassnola has a long history of dishonest and criminal conduct, his testimony in the SDNY trial was motivated by self-interest, and his statements should not be accepted as credible and persuasive in this NCAA infractions matter."