Plaintiffs’ Pleadings

Plaintiffs’ Motion Record For Certification

Tab Document Date
1. Notice of Motion February 20, 2015
A. Schedule “A” Draft Consolidated Fresh Statement of Claim Undated
2. Affidavit of Samuel Berg February 18, 2015
A. Amended Statement of Claim, Court File No.: CV-14-514423 November 5, 2014
B. Statement of Claim, Court File No.: CV-14-515637 00CP November 5, 2014
C. Statement of Claim, Court File No.: CV-15-519219 00CP January 6, 2015
D. OHL Standard Player Agreement Form between Niagara IceDogs and Sam Berg August 31, 2013
E. Statistics for Sam Berg from OHL website September 10, 2013

– December 31, 2013

F. CHL Press Release and Letter to the Editor October 20, 2014 & October 27, 2014
G. Statistics for Sam Berg from GOJHL website November 2, 2013

– January 2, 2014

H. Niagara IceDogs Results and Schedule 2013-2014
I. OHL Attendance Graph 2013-2014
J. Niagara Ice Dogs “Support Our Partners” website page February 17, 2015
K. OHL “livestream” packages website page February 17, 2015
L. Schedule “C” to the OHL Standard Player Agreement Undated
M. Litigation Plan February 18, 2015
3. Affidavit of Andrew J. Eckart  February 20, 2015
A. CHL Federal Corporation Information from Industry Canada February 19, 2015
B. Various pages from CHL website February 19, 2015
C. Corporate profile report for the Ontario Major Junior Hockey League October 2, 2014
D. Various pages from OHL website Undated
E. Pages 1-67 of 2013-2014 OHL Media Information Guide Undated
F. Email from Lisa Talbot February 12, 2015
G. Draft Consolidated Fresh Statement of Claim February 20, 2015
H. Western Hockey League Federal Corporation Information from Industry Canada February 19, 2015
I. Various pages from WHL website Undated
J. Various pages from WHL team websites Undated
K. News article “Bruce Hamilton back at helm of WHL Board”, Kelowna Capital News June 12, 2014
L. Revenu Quebec, Corporate Profile for Quebec Major Junior Hockey League Inc. profile report February 19, 2015
M. Various pages from QMJHL website Undated
N.  McCrimmon Holdings Ltd. v. Canada (Minister of National Revenue – M.N.R.), [2000] T.C.J. No. 823. November 24, 2000
O.  Redacted WHL  Standard Player Agreement Execution Schedule September 1, 2007
P. WHL Standard Player Agreement between Lukas Walter and the Tri-City Americans September 15, 2011
Q. Redacted OHL Standard Player Form 2007-2008
R. Redacted OHL Standard Player Form 2010-2011
S. Redacted Player Agreement in the QMJHL 2008
T. Redacted Player Agreement in the QMJHL 2010
U. CHLPA Press Release August 17, 2012
V. Statement from CHL President David Branch August 22, 2012
W. Toronto Star article entitled “Hockey player Joshua Desmond files suit against CHL for unpaid wages” October 31, 2012
X. Standard Contract between Lukas Walter and the Saint John Sea Dogs of the QMJHL September 10, 2013
Y. QMJHL Rights and Obligations of Players, R11 Manual September 2013
Z. News article from Yahoo Sports entitled “QMJHL drops overage salary to match OHL and WHL; predictably, potential overagers aren’t happy”. May 30, 2014
AA. Luke Walter Record of Employment March 17, 2014
BB. Luke Walter T4s 2013
CC. Various pages from Hockey Canada website Undated
DD. A copy of the USAH/HC/CHL Transfer and Release Agreement appended to the 2009-2010 Hockey Canada By-Laws 2009-2010
EE. CD containing:

a. Hockey Canada 2014-2015 Bylaws

b. Interview with David Branch on CBC’s Metro Morning, October 21, 2014

c. Interview with David Branch on Sportsnet Fan 590’s Prime Time Sports, October 21, 2014

Various dates
FF. NCAA 2014-2015 Bylaw Article 12, Amateurism 2014-2015
GG. A  joint press release posted on the CHL website October 20, 2014
HH. Article from the Toronto Star entitled “Star investigation: CHL claims questioned” February 17, 2015
II. About page from USA Hockey website February 19, 2015
JJ. Press release from OHL website Undated
KK. Press release from QMJHL website September 10, 2014
LL. Press release from WHL September 11, 2014
MM. Letter from NHL Deputy Commissioner William Daly to David Branch September 10, 2012
NN. Various blogs and websites discussing development fees Various Dates
OO. Articles 15 and 16 of the collective bargaining agreement between the National Hockey League and the National Hockey League Players’ Association Undated
PP. Various pages from the Professional Hockey Players’ Association website February 19, 2015
QQ. Northwestern University v. College Athletes Players Association (CAPA), Case 13-RC-121359 March 26, 2014
RR. Article from TSN.com entitled “Westhead: State Attorney recommends further labour probe of junior hockey” December 4, 2014
SS. Washington State House Bill 1930 and amendments February 3, 2015
4. Affidavit of Lukas Walter March 11, 2015
A. Invitation to Portland Winterhawks training camp Undated
B. Executed WHL Standard Players Agreement Contract between Lukas Walter and Tri-City Americans September 15, 2011
C. 1-797B Notice of Action Form Issued by the U.S.Department of Homeland Security July 31, 2012
D. WHL website statistics and record of games played for Lukas Walter with Tri-City Americans 2011 to 2013
E. Press release from the WHL website announcing the signing of Brendan Shinnimin to the Phoenix Coyotes March 2, 2012
F. Brendan Shinnimin’s hockey career statistics from hockeydb.com 2007 to 2015
G. Executed QMJHL Standard Form Contract between Lukas Walter and the Saint John Sea Dogs September 10, 2013
H. QMJHL Regulations R-11 Rights and Obligations of Players September, 2013
I. QMJHL website statistics and record of games played for Lukas Walter with Saint John Sea Dogs 2013-2014
J. Lukas Walter T4 Statement issued by Saint John Sea Dogs 2013
K. Lukas Walter T4 Statement issued by Saint John Sea Dogs 2014
L. Lukas Walter Record of Employment issued by the Saint John Sea Dogs March 17, 2014
M. Tri-City American Team Results and Schedule from hockeydb.com 2011 to 2013
N. WHL Attendance Graphs from hockeydb.com 2011 to 2013
O. Saint John Sea Dogs Team Results and Schedule from hockeydb.com 2013 to 2014
P. QMJHL Attendance Graph from hockeydb.com Undated
Q The “Sponsors” pages from the Tri-City Americans and Saint John Sea Dogs’ website Undated
R. WHL and QMJHL “livestream” packages pages from website Undated
 5. Affidavit of Bill Berg  March 11, 2015
A. Bill Berg’s career statistics from hockeydb.com 1985 to 1999
 6. Affidavit of Ryan Allen Hancock  March 31, 2015
A. Curriculum Vitae
B. CHL Class Action Report (with appendices) March 31, 2015
Appendix “A” – Copies of Washington State House Bill 1930 2015-2016 and Senate Bill 5893 2015-2016 Various dates
Appendix “B” – Administrative Policy of State of Washington, Department of Labor & Industries Employment Standards, No. ES.A.1 July 15, 2014
Appendix “C” – Announcement of Washington State Department of Labor & Industries FY15-309 December 2014
Appendix “D” – “Economic Reality Test” Handout from Oregon Bureau of Labor and Industries 2011
Appendix “E” – Cejas Commer. Interiors, Inc. v. Torres-Lizama, 260 Or. App. 87, 316 P.3d 389, 395 (Or. Ct. App. 2013) December 18, 2013
Appendix “F” – Letter from Oregon’s Bureau of Labor & Industries Commissioner Avakian September 17, 2014
Appendix “G” – Unemployment Insurance Agency publication 1982-L, Independent Contractors 2012
Appendix “H” – Buckley v. Prof’l Plaza Clinic Corp., 281 Mich. App. 224, 236; 761 N.W.2d 284 (2008) October 2, 2008
Appendix “I” – Michigan Occupational Safety and Health Administration’s required minimum wage poster Undated
Appendix “J” – Minimum Wage Law Summary of Pennsylvania Department of Labor & Industry, LLC-1 February 2012
Appendix “K” – Pennsylvania’s Child Labor Act Undated
Appendix “L” – Maine’s adopted “Employment Standard Defining Employee vs. Independent Contractor” Test 2013
Appendix “M” – Maine’s Department of Labor Minimum Wage Poster Undated
C. Acknowledgement of Expert’s Duty March 31, 2015

Plaintiffs’ Supplementary Motion Record For Certification

Tab Document Date
1 Affidavit of Kiara Sancler   November 19, 2015
A Agreement between the National Hockey League and Canadian Hockey League September 10, 2012
B Selected pages from the Collective Bargaining Agreement between the National Hockey League and its players September 16, 2012 – September 15, 2022
C Letter from the State of Washington, Department of Labor and Industries to the Spokane Chiefs (Hat Trick, Inc.) December 2, 2013
D Letter from Barry Alan Johnsrud to State of Washington, Labor and Industries with Exhibits “A” to “E” February 11, 2014
E Legal memorandum composed by Katy Dixon, Assistant Attorney General of Washington October 22, 2014
F Supplementary legal memorandum by Katy Dixon, Assistant Attorney General of Washington Undated
G Letter from the State of Washington, Department of Labor and Industries to Mr. Johnsrud December 30, 2014
H Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries re: Spokane Cheifs February 9, 2015
I Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries re: Seattle Thunderbirds February 9, 2015
J Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries Re: Tri-City Americans February 10, 2015
K Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries Re: Everett Silvertips February 13, 2015
L Article from Broadcaster Magazine entitled, “Sportsnet Announces Multiplatform Rights Extension with Canadian Hockey League” February 18, 2014
M Press release from CHL entitled, “CHL and Sportsnet Announce 12-Year Multiplatform Rights Extension” February 18, 2014
N Article from the StarPhoenix entitled, “WHL looking at tweak to player benefits” February 27, 2014
O Redacted WHL Standard Player Agreement 2013
P Redacted WHL Standard Player Agreement 2014
Q Selected pages from Prospects Hockey magazine Spring 2015
R Printout from CHL.ca showing the covers of past Editions of the magazine in English and French Undated
S Print-out of website entitled, “This is the CHL” Undated
T CD containing Episodes 1-8 of “This is the CHL” Various dates
U CD containing various videos posted on CHL.ca and YouTube.com Undated
V Press release posted on CHL.ca entitled, “2015 Canadian Hockey League Import Draft Results June 30, 2015
W Press release posted on CHL.ca entitled “405 CHL Grads Named to NHL Opening Day Rosters” October 7, 2015
X CHL Broadcast Schedule retrieved from CHL.ca November 13, 2015
Y Press release entitled, “OHL Announces 2015-16 Rule Changes” September 4, 2015
Z Press release entitled “WHL Announces 2015-16 Rule Changes” September 14, 2015
AA Article entitled, “Mario Cluina commits to Spitfires” September 3, 2015
BB Article entitled, “Ryan McGregor commits to Sting” September 3, 2015
CC Article entitled, “Colton Incze commits to IceDogs” September 5, 2015
DD Article entitled, “Joshua Dame commits to IceDogs” September 8, 2015
EE Article entitled, “Greg Meireles commits to Rangers” September 9, 2015
FF Article entitled, “Daniel Beaudoin commits to Spitfires” September 9, 2015
GG Article entitled, “Sting name Daniel Nikandrov captain” September 24, 2015
HH Article entitled, “Leafs prospect Jeremy Bracco commits to Rangers” October 28, 2015
II Article entitled, “Aidan McFarland commits to Steelheads” October 29, 2015
JJ Article entitled, “OHL Live Early Bird Pricing Now Available” September 22, 2015
KK OHL education policy webpage from CHL website November 13, 2015
LL WHL education policy webpage from CHL website November 13, 2015
MM QMJHL education policy from CHL website November 13, 2015
2 Affidavit of Samuel Berg (with exhibits) June 14, 2016
A Niagara IceDogs attendance statistics from HockeyAttendance.com and HockeyDB.com 2007-16
B Niagara IceDogs Corporate Partnership Available Inventory 2013-14
C Contract between Niagara IceDogs and City of St. Catharines, Schedule “B” Allocation of Revenue Between Parties Undated
D Article, “Steelheads comeback spoils IceDogs home opener”, Niagara This Week September 26, 2013
E Posting from Niagara IceDogs Instagram page November 30, 2015
F Niagara IceDogs Billet Calendar, September 2013 Undated
G OHL Announcement Regarding the Windsor Spitfires Undated
H “Hockey Operations” and “Business Staff” pages from Niagara IceDogs website Undated
I Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles Courteau June 2016
3 Plaintiff’s Litigation Plan June 15, 2016
4 Affidavit of Lukas Walter (with exhibits) June 14, 2016
A Tri-City Americans attendance statistics from HockeyAttendance.com and HockeyDB.com 2011-14
B “Home” page from Tri-City Americans website Undated
C QMJHL Standard Contract between Lukas Walter and the Saint John Sea Dogs September 10, 2013
D Lukas Walter Record of Employment with Saint John Major Junior Hockey Club Ltd. March 17, 2014
E Lukas Walter T4 Statements of Remuneration Paid from Saint John Major Junior Hockey Club Ltd. 2013, 2014
F Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles Courteau June 2016
5 Affidavit of Jeremy Gottzmann (with exhibits) June 8, 2016
A Jeremy Gottzmann career hockey statistics from OHL website 2009-12
B Various pages from JuniorHockeyTruth.com Undated
C OHL Standard Player Agreement between Jeremy Gottzmann and the Erie Otters June 22, 2009
D Letter from Owner and General Manager of the Erie Otters, Sherwood Bassin June 22, 2009
E Peterborough Petes Training Camp Tentative Itinerary August 31, 2011
F Video, “Harry Young vs Jeremy Gottzmann”, HockeyFights.com March 25, 2010
G Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles Courteau June 2016
6 Affidavit of John Paul Chartrand (with exhibits) June 9, 2016
A John Chartrand career hockey statistics from OHL website 2009-12
B John Chartrand career hockey statistics from QMJHL website 2009-12
C Toronto Jr. Canadiens Minor Bantam Budget 2006-07
D Letter from General Manager of the Niagara IceDogs David Brown May 4, 2009
E Niagara IceDogs Spring Training Camp Education Seminar for Parents and Athletes Undated
F Various pages from JuniorHockeyTruth.com Undated
G Email from David Brown June 8, 2009
H John Chartrand Niagara IceDogs Pre-Season Medical Evaluation July 30, 2009
I Niagara IceDogs Training Camp Rosters 2009
J Niagara IceDogs Training Camp Itinerary August 25-29, 2009
K OHL Standard Player Agreement between John Chartrand and the Niagara IceDogs August 30, 2009
L Game highlights video from BellevilleBulls.com Undated
M Video from IceDogsFans.com, “Andrews vs. O’Neil OHL hockey fight” October 2, 2010
N Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles Courteau June 2016
7 “Canadian Hockey League Player Study” by Chester Hanvey (with exhibits) June 15, 2016
A Exhibit “1” – Curriculum Vitae July 24, 2015
B Exhibit “2” – List of Documents Reviewed Various Dates
C Exhibit “3” – CHL Player Experience Interview Questionnaire Undated
D Exhibit “4” – CHL Player Job Analysis, Script 1: For Charney Lawyers to Schedule Player Interview May 24, 2016
E Exhibit “5” – CHL Player Job Analysis Script 2: Emil from Charney Lawyers to Player with Information about Interview May 24, 2016
F Exhibit “6” – CHL Player Experience Interview Responses Various Dates
8 “Report on the Economics of the Canadian Hockey League and its Team Members” by Dr. Kevin P. Mongeon June 14, 2016
A Curriculum Vitae June 2016
9 Report of Ryan A. Hancock June 15, 2016
A U.S. Department of Labour Wage and Hour Division, Fact Sheet #71: “Internship Programs Under the Fair Labor Standards Act April 2010
B U.S. Department of Labour Wage and Hour Division, Fact Sheet #18: “Section 13 (a)(3) Exemption for Seasonal Amusement or Recreational Establishments Under the Fair Labor Standards Act (FLSA)” July 2008
C Second Amended Complaint, Senne, et al v. Office of Commissioner of Baseball, et al. 3:14-cv-00608-JCS (2014) February 2, 2014
D Docket Report, Senne, et al v. Office of Commissioner of Baseball, et al. 3:14-cv-00608-JCS (2014) February 7, 2014 – May 23, 2016
E Case Management and Pretrial Order, Senne, et al v. Office of Commissioner of Baseball, et al. 3:14-cv-00608-JCS (2014) May 23, 2016
F Washington Senate Bill 6220 (1998) November 6, 1998
G U.S. Department of Labour Wage and Hour Division, Fact Sheet #35: “Joint Employment Under the Fair Labor Standards Act (FLSA) and Migrant and Seasonal Agricultural Worker Protection Act (MSPA)” January 2016
10 Affidavit of Brendan O’Grady June 15, 2016
A OHL Constitution Undated
B WHL Bylaws and Constitution February 4, 2013
C Hockey Canada Articles and By-Laws 2009-10
D Hockey Canada Articles and By-Laws 2014-15
E The Hockey Canada Canadian Development Model Parent Information Handbook
F Report of the Committee on International Hockey, Federal Minister of State, Fitness and Amateur Sport 1978
G Article, “Juniors will turn pro if Ottawa has its say” by Donald Ramsay, published by the Globe and Mail October 28, 1978
H Excerpts of the Canadian Hockey Review: Interim Report on Minor Amateur Hockey in Canada, Federal Minister of State for Fitness and Amateur Sport March 1,1979
I Excerpts from Law of Hockey by John Barnes (Lexis Nexis, 2010) 2010
J Excerpts from the Sixth Report of the Parliamentary Standing Committee on Canadian Heritage, Sub-Committee On The Study Of Sport in Canada December 1998
K Excerpts from the transcript of a hearing before the Sub-Committee On The Study Of Sport in Canada November 5, 1998
L Excerpts from the transcript of debates at the Parliamentary Standing Committee on Finance on Bill 285, An Act to amend the Income Tax Act (exclusion of income received by an athlete from a non-profit club, society or association). November 22, 2005
M Court file for McCrimmon Holdings Ltd and 32155 Manitoba Ltd v Minister of National Revenue, Court File Number 2000-1538. 2000
N Article, “Junior teams to get primer in tax law” by Allan Maki, published by the Globe and Mail March 1, 2003
O Redacted T4 Forms for the 2010, 2011, 2012 Tax Years 2010-14
P Excerpts from the Canada Revenue Agency Employers’ Guide: Payroll Deductions and Remittances 2014
Q Canada Revenue Agency guideline entitled, “Athletes and Players Employed by Football, Hockey and Similar Clubs” September 4, 2002
R Article, “Learning About the Western Hockey League and Major Junior Hockey” by Travis Hair, published by SB Nation February 23, 2010
S Article, “Franchise values a good indicator of a rosy future” by David Naylor, published by the Globe and Mail May 20, 2005
T Article, “Junior-A Leaders Feeling the Freeze” by Ken Campbell, published by the Hockey News February 26, 2008
U “Fun Facts” printout from the CHL.ca March 2008
V Letter to David Branch in his capacity as President of the CHL, from William Daly, Deputy Commissioner of the NHL September 10, 2012
W Article, “WHL hammers Portland Winterhawks for league violations” by David Ebner, published by the Globe and Mail November 28, 2012
X Press release from the OHL entitled, “OHL Announces Fines / Sanctions” August 10, 2012
Y Article, “Ousted Oshawa Generals president awarded $450,000” by Jeff Mitchell, published by Metroland Media August 21, 2013
Z Article, “Local auto dealer Mike Priestner now big wheel in WHL with Saskatoon Blades purchase” by Jim Matheson, published by the Edmonton Journal September 5, 2013
AA White paper report entitled, “The Commercial Potential of Junior Hockey in Canada” by Mitch Thompson of Trojan One Consulting Group November 2013
BB Print-out from HockeyAttendance.com re OHL June 15, 2016
CC Print-out from HockeyAttendance.com re WHL June 15, 2016
DD Letter from Steve Bienkowski, COO and Governor of the Kitchener Rangers July 28, 2014
EE Article, “Business comes first for OHL” by Morris Dalla Costa, published by the London Free Press October 29, 2014
FF Article, “Major Junior Leagues Under Fire from Disgruntled Ex-Players” by Rick Westhead published by TSN November 1, 2014
GG Article, “Financial success continues for Swift Current Broncos during 2014/15” by Matthew Liebenberg, published by the Prairie Post October 9, 2015
HH Article, “Graham Lee: WHL saviour, concert king, entrepreneur” by Mike Devlin, published by the Times Colonist October 24, 2014
II Article, “Quebec Remparts sold for between $20 million and $25 million: Source” by Ken Campbell, published by the Hockey News November 27, 2014
JJ Article, “CHL lawsuit symbolizes larger struggle in elite amateur sport” by Adam Proteau, published by the Hockey News October 20, 2014
KK Article, “Ex-owner of junior hockey team to get $1.4M from sale”, published by the Associated Press August 12, 2015
LL Article, “CHL has no intentions of changing underage rules, AHL exemptions” published by the Canadian Press May 26, 2016
MM Article entitled “Mitch Marner’s dominant season opens up debates on NHL-CHL agreement” by Kelly Friesen and published by Yahoo! Buzzing the Net June 2, 2016
NN Printout of the webpage for the OHL’s online streaming service to view games June 15, 2016
OO Printout of the webpage for the WHL’s online streaming service to view games June 15, 2016
PP Article, “Tri-City Americans to Stay in Kennewick for another 5 years”, by Annie Fowler, published by the Tri-City Herald October 15, 2015
QQ Article, “Great Lake Loons, Saginaw Spirit pump $38 million into region’s economy”, by Cheryl Wade, published by the Midland Daily News January 28, 2015
RR Article, “Mark Sutcliffe: Jeff Hunt adjusting to life as part of OSEG” by Mark Sutcliffe, published by the Ottawa Citizen September 28, 2013
SS Printout from the Katz Group of Companies website June 15, 2016
TT Printout from the Calgary Hitmen’s website June 15, 2016
UU Chart compiled by Andra Dragoste February 2016
VV Hockey Canada 2014-15 Annual Report 2014-15
WW Article, “Windsor businessman and land developer Rucco Tullio fulfilled a dream Thursday”, published by the Windsor Star September 7, 2007
XX Article, “WHL tries to explain Bruins move”, published by The Chilliwack Progress April 20, 2011
YY Article, “Raiders proposed to bolster finances with private money” by Drew Wilson, published by Prince Albert Now May 24, 2011
ZZ Article, “OHL: Brampton Battalion moving to North Bay” by Daniel Girard, published by The Toronto Star December 26, 2012
AAA Article, “Ownership suffering mounting losses on the ice and in the pocketbook”, published by the Toronto Sun January 31, 2014
BBB Article, “Sarnia Sting sold to Darian Hatcher and David Legwand”, published by the Sarnia Observer January 22, 2015
CCC Article, “Three franchises on move in busy day for OHL, AHL” by Mike Zeisberger, published by the Toronto Sun March 12, 2015
DDD Article, “Junior stars must either suffer goons or quit” by William Houston, published by the Globe and Mail April 11, 1998
EEE Article, “How much money do junior hockey teams make?” by Ryan Kennedy, published by the Hockey News July 30, 2014.
FFF Article, “Westhead: Ex-OHL owner says clubs make millions on ‘back of kids,’ then ‘wash their hands of them’” by Rick Westhead, published by TSN November 17, 2014
GGG Article, “The Whl’s Winter Wonderland” by Patrick King, published by WHL.ca February 20, 2011
HHH Article, “Sting Trade Chiarlitti” by Paul Owen, published by the Sarnia Observer August 29, 2012
III Article, “Giants, Hitmen complete massive five-player trade” published by Vancouver Metro October 27, 2015
JJJ Article, “Steelheads look to steal the show” by David Shoalts, published by the Globe and Mail March 31, 2016
KKK Article, “Junior Hockey growing like nobody’s business” by Ryan Pyette and published by the Toronto Sun October 19, 2012
LLL Article, “Call them hockey players or amateurs, but don’t call them employees” by Ken Campbell and published by the Hockey News May 19, 2015
MMM Article, “Black & Blue” by Patrick O’Sullivan and published by The Player’s Tribune December 9, 2015
NNN Article, “Hockey’s Puppy Mill: A former junior player takes the chl to court” by Nicholas Hune-Brown and published by The Walrus Magazine November 20, 2015
OOO Three articles entitled “Inside the Ottawa 67’s”, Parts 1 to 3, by Shannon Proudfoot and published by Sportsnet March 8, 2016, March 10, 2016, March 15, 2016
PPP Article, “Junior program springboard to NHL” by Matt Higgins, published by the National Post April 25, 2016
QQQ Article, “The Time is Right for a Major Junior Hockey Players’ Association” by Jamie McKinven published on GlassAndOut.com July 15, 2014
RRR The NHL Standard Player Agreement, Exhibit 1 to the Collective Bargaining Agreement between the National Hockey League and the National Hockey League Players’ Association September 16, 2012 – September 15, 2022
SSS Article, “Derek Boogaard: A Boy Learns to Brawl” by John Branch, published by the New York Times December 3, 2011
TTT Article, “Sutch: What we can all learn from Trafford tragedy” by Gregg Sutch and published by Yahoo! Buzzing the Net March 17, 2014
UUU Article entitled “Ex-NHL prospect Gregg Sutch explains how he fell out of love with hockey” by John Matisz and published by Postmedia February 19, 2016
VVV Article, “Tyler Boston and the Difficulties of Balancing Junior Hockey and Education” by Joshua Kloke, published by Vice Magazine January 15, 2016
WWW Press release from the WHL entitled, “35 WHL Players Selected in 2015 NHL Draft” June 2015
XXX Press release from the OHL entitled, “31 OHL Players Selected in 2015 NHL Draft” June 2015
YYY Printout from NHL.com with Draft Statistic 2000 and 2014
ZZZ Press release from the CHL entitled, “Statement from CHL President David Branch” August 22, 2012
AAAA Article, “CHLPA or not, junior hockey needs to stop screwing its players, ban midseason trades” by Rob Granatstein, published by Postmedia August 22, 2012
BBBB Blog post from Jerry Dias entitled, “Time to pay ‘amateur’ jr hockey players”, published January 26, 2015
CCCC Article, “Peterborough Petes’ Bob Neville new chairman, president of OHL board of governors” by Mike Davies, published by Sun Media August 13, 2013
DDDD Article, “OHL ups the ante, makes significant changes to player benefit packages” by Sunaya Sapurji, published by Yahoo! Buzzing the Net February 20, 2014
EEEE Article, “Major junior hockey union new mission for player turned activist” by Robert Cribb and Rick Westhead, published by the Toronto Star July 8, 2014
FFFF Article, “Jason Gregor: WHL needs to change draft age” by Jason Gregor and published by the Edmonton Journal February 10, 2016
GGGG Article, “NCAA vs. CHL: Summer of Decommitments Rages On” by Chris Peters and published by The United States of Hockey August 19, 2013
HHHH Memorandum by Andra Dragoste on the number of Canadian players on WHL and OHL teams during the 2015/16 season February 2016
IIII Letter from Andrew Eckart, then a lawyer with Charney Lawyers, to Patricia Jackson, partner at Torys LLP (“Torys”), counsel for the defence May 6, 2015
JJJJ Letter from Crawford Smith to Ted Charney May 27, 2015
KKKK Email correspondence between Crawford Smith and Ted Charney May 29, 2015 – June 1, 2015
LLLL Email correspondence between Crawford Smith and Ted Charney February 4, 2016
MMMM Memorandum composed by Ted Charney February 9, 2016
NNNN Email correspondence between Emmanuel Laurin Legare and Sylvie Rodrigue September 4, 2015
OOOO Letter between Ted Charney and Patricia Jackson September 16, 2015 – September 18, 2015
PPPP AIG Insurance Company of Canada Not-for-Profit Individual and Organizational Insurance Policy Including Employment Practices Liability Insurance # 04 540 69 73 September 1, 2014 – September 1, 2017
QQQQ AIG Insurance Company of Canada, Director, Officers and Private Company Liability Insurance Policy Including Employment Practices and Securities Liability # 04 540 69 74 September 1, 2014 – September 1, 2015
RRRR Chubb Insurance Excess Policy # 6803-0917 September 1, 2014 – September 1, 2017
SSSS The Guarantee Company of North America Follow Form, Directors and Officers Liability Insurance Policy #120534-10 September 1, 2014 to September 1, 2015
TTTT Encon PrivatePlus Private Entity, Management Liability Insurance Policy # PV-396351 December 11, 2013 – December 11, 2015
UUUU Encon PrivatePlus Private Entity, Management Liability Insurance Policy # PV-436076 May 22, 2014 – May 22, 2015
VVVV Letter from Ted Charney to Patricia Jackson September 18, 2015
WWWW Letter from Crawford Smith to Ted Charney June 2, 2016
11 Affidavit of Victoria Grygar (with exhibits) June 11, 2016
A Article, “Former OHLer Milan Doczy denied educational scholarship funding”, Toronto Star December 26, 2012
B M.A. Thesis, “A Struggle Against the Odds: Understanding the Lived Experiences of Canadian Hockey League (CHL) Players”, by Victoria Grygar August 2013
C Abstract, “Reclaiming the rights of youth: A preliminary analysis of the lived experiences of Canadian Hockey League (CHL) players”, by Victoria Grygar Undated
D Transcripts, Victoria Grygar interviews with 11 CHL players January 29, 2013 – March 15, 2013
E Letter from Victoria Grygar, “What the $%&! is going on with major junior hockey?: An open letter to David Branch March 18, 2013
F Niagara IceDogs Corporate Partnership Available Inventory 2013-14
G Contract between Niagara IceDogs and City of St. Catharines, Schedule “B” Allocation of Revenue Between Parties Undated
H Unsigned agreement between player and QMJHL Club (redacted) Undated
I Signed agreement between player and QMJHL Club (redacted) 2008