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Plaintiffs’ Court Documents

QMJHL SPAs

The judge managing the class action in Quebec has ordered the defendants to produce the Standard Player Agreement (SPA) all players signed between 2008-2013.

The SPA ( both the English and French versions) was filed in Court on August 25 together with the affidavit of Gilles Courteau, Commissioner of the Quebec Major Junior Hockey League (“QMJHL”).

The SPA  was drafted by the QMJHL and approved by its Board of Governors comprised of the owners of every Club and the Commissioner. Section  3 is entitled “Employment and Duties of Player”. Section 3 sets out the services expected of the players. Section 2 is entitled “Remuneration” and provides that each player will be paid a Salary.

There can now be no question that for many years the QMJHL legally classified Major Junior Hockey Players as employees while failing to pay minimum wage in direct violation of Quebec labor laws.

Throughout the course of this litigation, the Commissioners of the QMJHL, the Ontario Hockey League (“OHL”), the Western Hockey League (“WHL”) and the Canadian Hockey League (“CHL”) have repeatedly denied that Major Junior Hockey Players are employees while insisting that the leagues have always considered Major Junior Hockey Players to be amateur athletes. These statements were made in circumstances where the Commissioners must have known that Major Junior Hockey approved a Standard Player Agreement where until 2013 players are characterized as employees.

In 2014, as a result of a union drive and this class action, all three leagues in concert cancelled existing standard player agreements and replaced them with a new agreement where players are characterized as amateur athletes.

To date class actions in Alberta and Ontario against the WHL and the OHL have been certified while the Quebec class action will be heard in the fall of 2017. Given the new evidence revealed by the release of the QMJHL SPA, we expect all courts will have no difficulty in finding Major Junior Hockey players are employees.

The QMJHL SPA can be accessed here.

Plaintiffs’ Pleadings

Select Plaintiffs’ Expert Reports

TabDocumentDate
1.  Notice of MotionFebruary 20, 2015
A.Schedule “A” Draft Consolidated Fresh Statement of Claim Undated
2.Affidavit of Samuel BergFebruary 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. EckartFebruary 20, 2015
A.CHL Federal Corporation Information from Industry CanadaFebruary 19, 2015
B.Various pages from CHL website February 19, 2015
C.Corporate profile report for the Ontario Major Junior Hockey LeagueOctober 2, 2014
D.Various pages from OHL websiteUndated
E.Pages 1-67 of 2013-2014 OHL Media Information GuideUndated
F.Email from Lisa TalbotFebruary 12, 2015
G.Draft Consolidated Fresh Statement of ClaimFebruary 20, 2015
H.Western Hockey League Federal Corporation Information from Industry CanadaFebruary 19, 2015
I.Various pages from WHL websiteUndated
J.Various pages from WHL team websitesUndated
K.News article “Bruce Hamilton back at helm of WHL Board”, Kelowna Capital NewsJune 12, 2014
L.Revenu Quebec, Corporate Profile for Quebec Major Junior Hockey League Inc. profile reportFebruary 19, 2015
M.Various pages from QMJHL websiteUndated
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 ScheduleSeptember 1, 2007
P.WHL Standard Player Agreement between Lukas Walter and the Tri-City AmericansSeptember 15, 2011
Q.Redacted OHL Standard Player Form2007-2008
R.Redacted OHL Standard Player Form2010-2011
S.Redacted Player Agreement in the QMJHL2008
T.Redacted Player Agreement in the QMJHL2010
U.CHLPA Press ReleaseAugust 17, 2012
V.Statement from CHL President David BranchAugust 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 QMJHLSeptember 10, 2013
Y.QMJHL Rights and Obligations of Players, R11 ManualSeptember 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 EmploymentMarch 17, 2014
BB.Luke Walter T4s2013
CC.Various pages from Hockey Canada websiteUndated
DD.A copy of the USAH/HC/CHL Transfer and Release Agreement appended to the 2009-2010 Hockey Canada By-Laws2009-2010
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, Amateurism2014-2015
GG.A  joint press release posted on the CHL websiteOctober 20, 2014
HH.Article from the Toronto Star entitled “Star investigation: CHL claims questioned”February 17, 2015
II.About page from USA Hockey websiteFebruary 19, 2015
JJ.Press release from OHL websiteUndated
KK.Press release from QMJHL websiteSeptember 10, 2014
LL.Press release from WHLSeptember 11, 2014
MM.Letter from NHL Deputy Commissioner William Daly to David BranchSeptember 10, 2012
NN.Various blogs and websites discussing development feesVarious Dates
OO.Articles 15 and 16 of the collective bargaining agreement between the National Hockey League and the National Hockey League Players’ AssociationUndated
PP.Various pages from the Professional Hockey Players’ Association websiteFebruary 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 amendmentsFebruary 3, 2015
4.Affidavit of Lukas WalterMarch 11, 2015
A.Invitation to Portland Winterhawks training campUndated
B.Executed WHL Standard Players Agreement Contract between Lukas Walter and Tri-City AmericansSeptember 15, 2011
C.1-797B Notice of Action Form Issued by the U.S.Department of Homeland SecurityJuly 31, 2012
D.WHL website statistics and record of games played for Lukas Walter with Tri-City Americans2011 to 2013
E.Press release from the WHL website announcing the signing of Brendan Shinnimin to the Phoenix CoyotesMarch 2, 2012
F.Brendan Shinnimin’s hockey career statistics from hockeydb.com2007 to 2015
G.Executed QMJHL Standard Form Contract between Lukas Walter and the Saint John Sea DogsSeptember 10, 2013
H.QMJHL Regulations R-11 Rights and Obligations of PlayersSeptember, 2013
I.QMJHL website statistics and record of games played for Lukas Walter with Saint John Sea Dogs2013-2014
J.Lukas Walter T4 Statement issued by Saint John Sea Dogs2013
K.Lukas Walter T4 Statement issued by Saint John Sea Dogs2014
L.Lukas Walter Record of Employment issued by the Saint John Sea DogsMarch 17, 2014
M.Tri-City American Team Results and Schedule from hockeydb.com2011 to 2013
N.WHL Attendance Graphs from hockeydb.com2011 to 2013
O.Saint John Sea Dogs Team Results and Schedule from hockeydb.com2013 to 2014
P.QMJHL Attendance Graph from hockeydb.comUndated
Q.The “Sponsors” pages from the Tri-City Americans and Saint John Sea Dogs’ websiteUndated
R.WHL and QMJHL “livestream” packages pages from websiteUndated
5.Affidavit of Bill BergMarch 11, 2015
A.Bill Berg’s career statistics from hockeydb.com1985 to 1999
6.Affidavit of Ryan Allen HancockMarch 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 2015-2016Various dates
 Appendix “B” – Administrative Policy of State of Washington, Department of Labor & Industries Employment Standards, No. ES.A.1July 15, 2014
 Appendix “C” – Announcement of Washington State Department of Labor & Industries FY15-309December 2014
 Appendix “D” – “Economic Reality Test” Handout from Oregon Bureau of Labor and Industries2011
 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 AvakianSeptember 17, 2014
 Appendix “G” – Unemployment Insurance Agency publication 1982-L, Independent Contractors2012
 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 posterUndated
 Appendix “J” – Minimum Wage Law Summary of Pennsylvania Department of Labor & Industry, LLC-1February 2012
 Appendix “K” – Pennsylvania’s Child Labor ActUndated
 Appendix “L” – Maine’s adopted “Employment Standard Defining Employee vs. Independent Contractor” Test2013
 Appendix “M” – Maine’s Department of Labor Minimum Wage PosterUndated
C.Acknowledgement of Expert’s DutyMarch 31, 2015

Plaintiffs’ Supplementary Motion Record For Certification 

TabDocumentDate
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. JohnsrudDecember 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 ThunderbirdsFebruary 9, 2015
J.Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries Re: Tri-City AmericansFebruary 10, 2015
K.Letter from Barry Alan Johnsrud to State of Washington, Department of Labor and Industries Re: Everett SilvertipsFebruary 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 Agreement2013
P.Redacted WHL Standard Player Agreement2014
Q.Selected pages from Prospects Hockey magazineSpring 2015
R.Printout from CHL.ca showing the covers of past Editions of the magazine in English and FrenchUndated
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.comUndated
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.caNovember 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 websiteNovember 13, 2015
LL.WHL education policy webpage from CHL websiteNovember 13, 2015
MM.QMJHL education policy from CHL websiteNovember 13, 2015
2.Affidavit of Samuel Berg (with exhibits)June 14, 2016
A.Niagara IceDogs attendance statistics from HockeyAttendance.com and HockeyDB.com2007-16
B.Niagara IceDogs Corporate Partnership Available Inventory2013-14
C.Contract between Niagara IceDogs and City of St. Catharines, Schedule “B” Allocation of Revenue Between PartiesUndated
D.Article, “Steelheads comeback spoils IceDogs home opener”, Niagara This WeekSeptember 26, 2013
E.Posting from Niagara IceDogs Instagram pageNovember 30, 2015
F.Niagara IceDogs Billet Calendar, September 2013Undated
G.OHL Announcement Regarding the Windsor SpitfiresUndated
H.“Hockey Operations” and “Business Staff” pages from Niagara IceDogs websiteUndated
I.Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles CourteauJune 2016
3.Plaintiff’s Litigation PlanJune 15, 2016
4.Affidavit of Lukas Walter (with exhibits)June 14, 2016
A.Tri-City Americans attendance statistics from HockeyAttendance.com and HockeyDB.com2011-14
B.“Home” page from Tri-City Americans websiteUndated
C.QMJHL Standard Contract between Lukas Walter and the Saint John Sea DogsSeptember 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 CourteauJune 2016
5.Affidavit of Jeremy Gottzmann (with exhibits)June 8, 2016
A.Jeremy Gottzmann career hockey statistics from OHL website2009-12
B.Various pages from JuniorHockeyTruth.comUndated
C.OHL Standard Player Agreement between Jeremy Gottzmann and the Erie OttersJune 22, 2009
D.Letter from Owner and General Manager of the Erie Otters, Sherwood BassinJune 22, 2009
E.Peterborough Petes Training Camp Tentative ItineraryAugust 31, 2011
F.Video, “Harry Young vs Jeremy Gottzmann”, HockeyFights.comMarch 25, 2010
G.Letter from OHL Commissioner David Branch, WHL Commissioner Ron Robison, QMJHL Commissioner Gilles CourteauJune 2016
6.Affidavit of John Paul Chartrand (with exhibits)June 9, 2016
A.John Chartrand career hockey statistics from OHL website2009-12
B.John Chartrand career hockey statistics from QMJHL website2009-12
C.Toronto Jr. Canadiens Minor Bantam Budget2006-07
D.Letter from General Manager of the Niagara IceDogs David BrownMay 4, 2009
E.Niagara IceDogs Spring Training Camp Education Seminar for Parents and AthletesUndated
F.Various pages from JuniorHockeyTruth.comUndated
G.Email from David BrownJune 8, 2009
H.John Chartrand Niagara IceDogs Pre-Season Medical EvaluationJuly 30, 2009
I.Niagara IceDogs Training Camp Rosters2009
J.Niagara IceDogs Training Camp ItineraryAugust 25-29, 2009
K.OHL Standard Player Agreement between John Chartrand and the Niagara IceDogsAugust 30, 2009
L.Game highlights video from BellevilleBulls.comUndated
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 CourteauJune 2016
7.“Canadian Hockey League Player Study” by Chester Hanvey (with exhibits)June 15, 2016
A.Exhibit “1” – Curriculum VitaeJuly 24, 2015
B.Exhibit “2” – List of Documents ReviewedVarious Dates
C.Exhibit “3” – CHL Player Experience Interview QuestionnaireUndated
D.Exhibit “4” – CHL Player Job Analysis, Script 1: For Charney Lawyers to Schedule Player InterviewMay 24, 2016
E.Exhibit “5” – CHL Player Job Analysis Script 2: Emil from Charney Lawyers to Player with Information about InterviewMay 24, 2016
F.Exhibit “6” – CHL Player Experience Interview ResponsesVarious Dates
8.“Report on the Economics of the Canadian Hockey League and its Team Members” by Dr. Kevin P. MongeonJune 14, 2016
A.Curriculum VitaeJune 2016
9.Report of Ryan A. HancockJune 15, 2016
A.U.S. Department of Labour Wage and Hour Division, Fact Sheet #71: “Internship Programs Under the Fair Labor Standards ActApril 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’GradyJune 15, 2016
A.OHL ConstitutionUndated
B.WHL Bylaws and ConstitutionFebruary 4, 2013
C.Hockey Canada Articles and By-Laws2009-10
D.Hockey Canada Articles and By-Laws2014-15
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 Sport1978
G.Article, “Juniors will turn pro if Ottawa has its say” by Donald Ramsay, published by the Globe and MailOctober 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 SportMarch 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 CanadaDecember 1998
K.Excerpts from the transcript of a hearing before the Sub-Committee On The Study Of Sport in CanadaNovember 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 MailMarch 1, 2003
O.Redacted T4 Forms for the 2010, 2011, 2012 Tax Years2010-14
P.Excerpts from the Canada Revenue Agency Employers’ Guide: Payroll Deductions and Remittances2014
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 NationFebruary 23, 2010
S.Article, “Franchise values a good indicator of a rosy future” by David Naylor, published by the Globe and MailMay 20, 2005
T.Article, “Junior-A Leaders Feeling the Freeze” by Ken Campbell, published by the Hockey NewsFebruary 26, 2008
U.“Fun Facts” printout from the CHL.caMarch 2008
V.Letter to David Branch in his capacity as President of the CHL, from William Daly, Deputy Commissioner of the NHLSeptember 10, 2012
W.Article, “WHL hammers Portland Winterhawks for league violations” by David Ebner, published by the Globe and MailNovember 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 MediaAugust 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 JournalSeptember 5, 2013
AA.White paper report entitled, “The Commercial Potential of Junior Hockey in Canada” by Mitch Thompson of Trojan One Consulting GroupNovember 2013
BB.Print-out from HockeyAttendance.com re OHLJune 15, 2016
CC.Print-out from HockeyAttendance.com re WHLJune 15, 2016
DD.Letter from Steve Bienkowski, COO and Governor of the Kitchener RangersJuly 28, 2014
EE.Article, “Business comes first for OHL” by Morris Dalla Costa, published by the London Free PressOctober 29, 2014
FF.Article, “Major Junior Leagues Under Fire from Disgruntled Ex-Players” by Rick Westhead published by TSNNovember 1, 2014
GG.Article, “Financial success continues for Swift Current Broncos during 2014/15” by Matthew Liebenberg, published by the Prairie PostOctober 9, 2015
HH.Article, “Graham Lee: WHL saviour, concert king, entrepreneur” by Mike Devlin, published by the Times ColonistOctober 24, 2014
II.Article, “Quebec Remparts sold for between $20 million and $25 million: Source” by Ken Campbell, published by the Hockey NewsNovember 27, 2014
JJ.Article, “CHL lawsuit symbolizes larger struggle in elite amateur sport” by Adam Proteau, published by the Hockey NewsOctober 20, 2014
KK.Article, “Ex-owner of junior hockey team to get $1.4M from sale”, published by the Associated PressAugust 12, 2015
LL.Article, “CHL has no intentions of changing underage rules, AHL exemptions” published by the Canadian PressMay 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 NetJune 2, 2016
NN.Printout of the webpage for the OHL’s online streaming service to view gamesJune 15, 2016
OO.Printout of the webpage for the WHL’s online streaming service to view gamesJune 15, 2016
PP.Article, “Tri-City Americans to Stay in Kennewick for another 5 years”, by Annie Fowler, published by the Tri-City HeraldOctober 15, 2015
QQ.Article, “Great Lake Loons, Saginaw Spirit pump $38 million into region’s economy”, by Cheryl Wade, published by the Midland Daily NewsJanuary 28, 2015
RR.Article, “Mark Sutcliffe: Jeff Hunt adjusting to life as part of OSEG” by Mark Sutcliffe, published by the Ottawa CitizenSeptember 28, 2013
SS.Printout from the Katz Group of Companies websiteJune 15, 2016
TT.Printout from the Calgary Hitmen’s websiteJune 15, 2016
UU.Chart compiled by Andra DragosteFebruary 2016
VV.Hockey Canada 2014-15 Annual Report2014-15
WW.Article, “Windsor businessman and land developer Rucco Tullio fulfilled a dream Thursday”, published by the Windsor StarSeptember 7, 2007
XX.Article, “WHL tries to explain Bruins move”, published by The Chilliwack ProgressApril 20, 2011
YY.Article, “Raiders proposed to bolster finances with private money” by Drew Wilson, published by Prince Albert NowMay 24, 2011
ZZ.Article, “OHL: Brampton Battalion moving to North Bay” by Daniel Girard, published by The Toronto StarDecember 26, 2012
AAA.Article, “Ownership suffering mounting losses on the ice and in the pocketbook”, published by the Toronto SunJanuary 31, 2014
BBB.Article, “Sarnia Sting sold to Darian Hatcher and David Legwand”, published by the Sarnia ObserverJanuary 22, 2015
CCC.Article, “Three franchises on move in busy day for OHL, AHL” by Mike Zeisberger, published by the Toronto SunMarch 12, 2015
DDD.Article, “Junior stars must either suffer goons or quit” by William Houston, published by the Globe and MailApril 11, 1998
EEE.Article, “How much money do junior hockey teams make?” by Ryan Kennedy, published by the Hockey NewsJuly 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 TSNNovember 17, 2014
GGG.Article, “The Whl’s Winter Wonderland” by Patrick King, published by WHL.caFebruary 20, 2011
HHH.Article, “Sting Trade Chiarlitti” by Paul Owen, published by the Sarnia ObserverAugust 29, 2012
III.Article, “Giants, Hitmen complete massive five-player trade” published by Vancouver MetroOctober 27, 2015
JJJ.Article, “Steelheads look to steal the show” by David Shoalts, published by the Globe and MailMarch 31, 2016
KKK.Article, “Junior Hockey growing like nobody’s business” by Ryan Pyette and published by the Toronto SunOctober 19, 2012
LLL.Article, “Call them hockey players or amateurs, but don’t call them employees” by Ken Campbell and published by the Hockey NewsMay 19, 2015
MMM.Article, “Black & Blue” by Patrick O’Sullivan and published by The Player’s TribuneDecember 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 MagazineNovember 20, 2015
OOO.Three articles entitled “Inside the Ottawa 67’s”, Parts 1 to 3, by Shannon Proudfoot and published by SportsnetMarch 8, 2016, March 10, 2016, March 15, 2016
PPP.Article, “Junior program springboard to NHL” by Matt Higgins, published by the National PostApril 25, 2016
QQQ.Article, “The Time is Right for a Major Junior Hockey Players’ Association” by Jamie McKinven published on GlassAndOut.comJuly 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’ AssociationSeptember 16, 2012 – September 15, 2022
SSS.Article, “Derek Boogaard: A Boy Learns to Brawl” by John Branch, published by the New York TimesDecember 3, 2011
TTT.Article, “Sutch: What we can all learn from Trafford tragedy” by Gregg Sutch and published by Yahoo! Buzzing the NetMarch 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 PostmediaFebruary 19, 2016
VVV.Article, “Tyler Boston and the Difficulties of Balancing Junior Hockey and Education” by Joshua Kloke, published by Vice MagazineJanuary 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 Statistic2000 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 PostmediaAugust 22, 2012
BBBB.Blog post from Jerry Dias entitled, “Time to pay ‘amateur’ jr hockey players”, publishedJanuary 26, 2015
CCCC.Article, “Peterborough Petes’ Bob Neville new chairman, president of OHL board of governors” by Mike Davies, published by Sun MediaAugust 13, 2013
DDDD.Article, “OHL ups the ante, makes significant changes to player benefit packages” by Sunaya Sapurji, published by Yahoo! Buzzing the NetFebruary 20, 2014
EEEE.Article, “Major junior hockey union new mission for player turned activist” by Robert Cribb and Rick Westhead, published by the Toronto StarJuly 8, 2014
FFFF.Article, “Jason Gregor: WHL needs to change draft age” by Jason Gregor and published by the Edmonton JournalFebruary 10, 2016
GGGG.Article, “NCAA vs. CHL: Summer of Decommitments Rages On” by Chris Peters and published by The United States of HockeyAugust 19, 2013
HHHH.Memorandum by Andra Dragoste on the number of Canadian players on WHL and OHL teams during the 2015/16 seasonFebruary 2016
IIII.Letter from Andrew Eckart, then a lawyer with Charney Lawyers, to Patricia Jackson, partner at Torys LLP (“Torys”), counsel for the defenceMay 6, 2015
JJJJ.Letter from Crawford Smith to Ted CharneyMay 27, 2015
KKKK.Email correspondence between Crawford Smith and Ted CharneyMay 29, 2015 – June 1, 2015
LLLL.Email correspondence between Crawford Smith and Ted CharneyFebruary 4, 2016
MMMM.Memorandum composed by Ted CharneyFebruary 9, 2016
NNNN.Email correspondence between Emmanuel Laurin Legare and Sylvie RodrigueSeptember 4, 2015
OOOO.Letter between Ted Charney and Patricia JacksonSeptember 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 73September 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 74September 1, 2014 – September 1, 2015
RRRR.Chubb Insurance Excess Policy # 6803-0917September 1, 2014 – September 1, 2017
SSSS.The Guarantee Company of North America Follow Form, Directors and Officers Liability Insurance Policy #120534-10September 1, 2014 to September 1, 2015
TTTT.Encon PrivatePlus Private Entity, Management Liability Insurance Policy # PV-396351December 11, 2013 – December 11, 2015
UUUU.Encon PrivatePlus Private Entity, Management Liability Insurance Policy # PV-436076May 22, 2014 – May 22, 2015
VVVV.Letter from Ted Charney to Patricia JacksonSeptember 18, 2015
WWWW.Letter from Crawford Smith to Ted CharneyJune 2, 2016
11.Affidavit of Victoria Grygar (with exhibits)June 11, 2016
A.Article, “Former OHLer Milan Doczy denied educational scholarship funding”, Toronto StarDecember 26, 2012
B.M.A. Thesis, “A Struggle Against the Odds: Understanding the Lived Experiences of Canadian Hockey League (CHL) Players”, by Victoria GrygarAugust 2013
C.Abstract, “Reclaiming the rights of youth: A preliminary analysis of the lived experiences of Canadian Hockey League (CHL) players”, by Victoria GrygarUndated
D.Transcripts, Victoria Grygar interviews with 11 CHL playersJanuary 29, 2013 – March 15, 2013
E.letter from Victoria Grygar, “What the $%&! is going on with major junior hockey?: An open letter to David BranchMarch 18, 2013
F.Niagara IceDogs Corporate Partnership Available Inventory2013-14
G.Contract between Niagara IceDogs and City of St. Catharines, Schedule “B” Allocation of Revenue Between PartiesUndated
H.Unsigned agreement between player and QMJHL Club (redacted)Undated
I.Signed agreement between player and QMJHL Club (redacted)2008