United States District Court District of Minnesota in Re National Hockey Players' Concussion Injury Litigation Grant Ledyard
CASE 0:16-cv-00248 Document 1 Filed 02/03/16 Page 1 of 126 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA IN RE NATIONAL HOCKEY PLAYERS’ ) MDL No. 14-2551 (SRN/JSM) CONCUSSION INJURY LITIGATION ) ) ) GRANT LEDYARD, LINK GAETZ, Case No. _________________ DOUG BARRIE, JACK EGERS, DALE ) PURINTON, GARY DILLON, ROBERT ) CLASS ACTION COMPLAINT FLOCKHART, PAUL STEWART, ) STEVE JENSEN, SHAWN ANDERSON, ) Jury Trial Demanded NIKOS TSELIOS, and MICHAEL ) ROBITAILLE on behalf of themselves and ) all others similarly situated, ) ) Plaintiffs, ) ) v. ) ) NATIONAL HOCKEY LEAGUE, NHL ) ENTERPRISES, INC., and THE NHL ) BOARD OF GOVERNORS, ) ) Defendants. ) ___________________________________ ) 1115250_1 CASE 0:16-cv-00248 Document 1 Filed 02/03/16 Page 2 of 126 Plaintiffs, by and through undersigned counsel, for their Class Action Complaint sue herein on their own behalf and on behalf of the Class defined below, Defendant National Hockey League and its constituent entities, including, without limitation, NHL Enterprises, Inc., and the National Hockey League Board of Governors (collectively “Defendant,” “NHL,” or the “League”) and, pursuant to Fed. R. Civ. P. 11(b), allege upon facts and information and belief, except for the allegations concerning each Plaintiff’s own actions, as follows. INTRODUCTION 1. This lawsuit seeks relief on behalf of former NHL players not yet diagnosed with a neurodegenerative illness, this lawsuit seeks medical monitoring of present cellular and subcellular injuries caused by Defendant’s negligence, fraudulent concealment, fraud by omission, and failure to warn of the enhanced, long-term risk of contracting a neurodegenerative disease or condition from concussive and subconcussive impacts that occurred when they played in the NHL (the “Class”).
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