United States District Court District of Minnesota in Re
CASE 0:15-cv-04191 Document 1 Filed 11/23/15 Page 1 of 129 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA IN RE NATIONAL HOCKEY PLAYERS’ ) MDL No. 14-2551 (SRN/JSM) CONCUSSION INJURY LITIGATION ) ) ) CRAIG MUNI, WARREN “BUTCH” Case No. _________________ WILLIAMS, LANCE PITLICK, JASON ) DOIG, DENNIS MARUK, BOBBY ) CLASS ACTION COMPLAINT DOLLAS, GENE CARR, HARRY YORK, ) RON FLOCKHART, ROBERT ) Jury Trial Demanded MURDOCH, BLAINE STOUGHTON, ) FRANK SPRING, DON MURDOCH, ) TOM CASSIDY, CAM CONNOR, JIM ) HOFFORD, SASHA LAKOVIC, MARTIN ) SIMARD, SHAYNE STEVENSON, ) HAROLD DRUKEN, LYNDON BYERS, ) MICHAL PIVONKA, JOE DZIEDZIC, ) and BARRY SCOTT BJUGSTAD on ) behalf of themselves and all others ) similarly situated, ) ) Plaintiffs, ) ) v. ) ) NATIONAL HOCKEY LEAGUE, NHL ) ENTERPRISES, INC., and THE NHL ) BOARD OF GOVERNORS, ) ) Defendants. ___________________________________ CASE 0:15-cv-04191 Document 1 Filed 11/23/15 Page 2 of 129 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.
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