Oliwa, Stephens, Quint, Poeschek Complaint
CASE 0:15-cv-03904 Document 1 Filed 10/20/15 Page 1 of 106 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA IN RE NATIONAL HOCKEY PLAYERS’ ) MDL No. 14-2551 (SRN/JSM) CONCUSSION INJURY LITIGATION ) ) ) KRZYSZTOF OLIWA, KEVIN Case No. _______________ STEVENS, DERON QUINT, and RUDY ) POESCHEK, on behalf of themselves and ) CLASS ACTION COMPLAINT all others similarly situated, ) ) Jury Trial Demanded Plaintiffs, ) ) v. ) ) NATIONAL HOCKEY LEAGUE, NHL ) ENTERPRISES, INC., and THE NHL ) BOARD OF GOVERNORS, ) ) Defendants. ) ___________________________________ ) CASE 0:15-cv-03904 Document 1 Filed 10/20/15 Page 2 of 106 Plaintiffs, by and through multiple undersigned counsel, bring this Class Action Complaint against Defendant National Hockey League and its constituent entities, including, without limitation, NHL Enterprises, Inc., and the National Hockey League Board of Governors (“Board”) (collectively “Defendant,” “NHL,” or “League”) and, pursuant to Fed. R. Civ. P. 11(b), allege upon facts and information and belief, except for the allegations concerning each Plaintiffs’ own actions, as follows. INTRODUCTION 1. Former NHL players signed up to play hockey knowing that they might get injured and dinged, but they did not sign up for avoidable brain damage. This action arises from the pathological and debilitating effects of brain injuries caused by concussive and sub-concussive impacts sustained by former NHL players during their professional careers. 2. Every blow to the head is dangerous. Both repeated concussions and sub- concussions cause permanent brain damage. During practice and games, an NHL player can sustain close to one thousand or more hits to the head in one season without any documented incapacitating concussion.
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