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2016-08-03 - (Grand, Julie) Final REDACTED - Condensed
2016-08-03 - (Grand, Julie) Final REDACTED - Condensed
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1 UNITED STATES DISTRICT COURT
2 DISTRICT OF MINNESOTA
3
4 - - - - - - - - - - - - - - - - - - - - - - -x
5 In re: National Hockey League MDL
6 No. 14-2551 (SRN/JSM)
7 Players' Concussion Injury
8 Litigation
9 - - - - - - - - - - - - - - - - - - - - - -x
10
11
12
13
14
15 Videotaped deposition of JULIE GRAND, was
16 held at the Law Offices of SKADDEN, ARPS, SLATE,
17 MEAGHER & FLOM, LLP, Four Times Square, New York,
18 New York, commencing August 3, 2016, 9:02 a.m., on
19 the above date, before Amanda McCredo, a Court
20 Reporter and Notary Public in the State of New York.
21
---
22
23
24
25
Page 2 Page 4
1 A P P E A R A N C E S: 1 Exhibit 8 E-mail from Julie Grand to Bill 104
2 SILVERMAN, THOMPSON, SLUTKIN & WHITE Daly, Bates-stamped NHL1626501
Attorneys for Plaintiffs 2
Exhibit 9 E-mail from Julie Grand to Bill 132
3 201 N. Charles Street, Suite 2600
3 Daly dated May 24, 2010,
Baltimore, Maryland 21201 Bates-stamped NHL2110271 through
4 BY: STEPHEN G. GRYGIEL, ESQUIRE 4 273
sgrygiel@mdattorney.com 5 Exhibit 10 151
5 (410)385-2225 6 Exhibit 11 E-mail from Ruben Echemendia to 166
6 Winne Meeuwisse dated June 1,
7 GOLDMAN SCARLATO & PENNY, P.C. 7 2010, Bates-stamped NHL2243154
through 159
Attorneys for Plaintiffs
8
8 Eight Tower Bridge, Suite 1025 Exhibit 12 E-mail from Ruben Echemendia to 179
161 Washington Street 9 Julie Grand dated June 4, 2010,
9 Conshohocken, Pennsylvania 19428 Bates-stamped NHL1669037 through
BY: BRIAN D. PENNY, ESQUIRE 10 039
10 penny@lawgsp.com 11 Exhibit 13 E-mail from Ruben Echemendia to 182
(484)342-0700 Bill Daly and Julie Grand dated
11 12 September 24, 2010, Bates-stamped
NHL2135004 through 006
12
13
13 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Exhibit 14 E-mail from Willem Meeuwisse to 186
Attorneys for Defendants 14 Julie Grand dated October 29,
14 Four Times Square 2010, Bates-stamped NHL2087294
New York, New York 10036 15 through 298
15 BY: JAMES A. KEYTE, ESQUIRE 16 Exhibit 15 E-mail from Julie Grand to Bill 201
MATTHEW LISAGAR, ESQUIRE Daly dated March 2, 2011,
17 Bates-stamped NHL1787804
16 MATTHEW M. MARTINO, ESQUIRE
18 Exhibit 16 E-mail from Julie Grand to Gary 203
james.ketye@skadden.com Meagher and Bill Daly dated
17 matthew.lisagar@skadden.com 19 October 5, 2011, Bates-stamped
matthew.martino@skadden.com NHL182010 through 11
18 (212)735-3000 20
19 Exhibit 17 E-mail from Julie Grand to Bill 209
20 21 Daly dated February 10, 2012,
21 ALSO PRESENT: Bates-stamped NHL2304283 through
22 284
22 MANNY GARCIA - videographer
23 Exhibit 18 E-mail from Julie Grand to Bill 213
23 Daly dated May 1, 2012,
24 24 Bates-stamped NHL2254667
25 25
Page 3 Page 5
1 INDEX 1 Exhibit 19 E-mail from Julie Grand to Ruben 221
2 WITNESS EXAMINATION BY PAGE Echemendia and Winne Meeuwisse
3 Julie Grand Mr. Grygiel 3, 391 2 dated August 2, 2012,
4 Mr. Keyte 386 Bates-stamped NHL1783125 through
5 3 143
6 EXHIBITS 4 Exhibit 20 E-mail from Julie Grand to Gary 222
7 PLAINTIFFS' PAGE Bettman dated August 7, 2012,
8 Exhibit 1 E-mail from Julie Grand to Bill 43 5 Bates-stamped NHL2132286 through
288
Daly dated February 11, 2008,
6
9 Bates-stamped NHL 1971101
Exhibit 21 E-mail from Julie Grand to Ruben 228
10 Exhibit 2 Document entitled CWG Meeting 54
7 Echemendia dated September 18,
Summary: May 1, 2012 2013, Bates-stamped NHL2236425
11 Bates-stamped NHL2275298 through 8 through 427
303 9 Exhibit 22 NHL/NHLPA Concussion Subcommittee 233
12 Meeting November 4, 2013, 8:00
Exhibit 3 E-mail from Ruben Echemendia to 59 10 a.m. - 4:00 p.m. Westin Diplomat
13 Willem Meeuwisse Bates-stamped - Ft. Lauderdale/Hollywood, FL
NHL1352051 through 057 11 Minutes, Bates-stamped NHL0247818
14 through 826
Exhibit 4 Concussion - retired player study 66 12
15 from Julie Grand to Bill Daly Exhibit 23 E-mail from Dave Dryden to Julie 240
dated March 13, 2008, 13 Spar-Grand and Terry Kane,
16 Bates-stamped NHL2267898 Bates-stamped NHL2335906 through
17 Exhibit 5 E-mail from Ian Penny to Andrew 78 14 907
Wolfe and others dated January 15 Exhibit 24 E-mail from Julie Grand to Bill 248
18 28, 2009, Bates-stamped Daly, Bates-stamped NHL1827376
NHLPA_0001308 to 10 16 through 379
19 17 Exhibit 25 E-mail from Frank Brown to Julie 255
Grand dated September 11, 2006,
Exhibit 6 Concussion Report BOG Meeting 89
18 Bates-stamped NHL1975700
20 Dec. 2009, Bates-stamped
19 Exhibit 26 E-mail from Bill Daly to Julie 283
NHL2081309 through 1315
Grand dated January 26, 2012,
21 20 Bates-stamped NHL2062819 through
Exhibit 7 Minutes of a Meeting of the Board 101 820
22 of Governors of the National 21
Hockey League held at the Inn at Exhibit 27 E-mail from Julie Grand to Gary 288
23 Spanish Bay, Pebble Beach, 22 Bettman and others, dated March
California on December 15-16, 8, 2011, Bates-stamped NHL0231896
24 2009, Bates-stamped NHL0209404 23 through 897
through 416 24
25 25
Page 6 Page 8
1 Exhibit 28 E-mail from Ruben Echemendia to 301 1 THE VIDEOGRAPHER: This is the start of
Julie Grand dated November 15,
2 2013, Bates-stamped NHL2315339 2 media labeled Number 1 of the video recorded
through 344
3 3 deposition of Julie Grand in the matter of in re
Exhibit 29 E-mail from Colin Campbell to 308
4 Julie Grand and others dated May 4 National Hockey League Plaintiffs' Concussion
16, 2013, Bates-stamped
5 Injury Litigation on August the 3rd, 2016 at
5 NHL0130619 through 620
6 Exhibit 30 E-mail from Ruben Echemendia to 318 6 approximately 9:02 a.m.
Julie Grand dated September 14,
7 2007, Bates-stamped NHL2131171 7 My name is Manny Garcia. I'm the video
through 172
8 8 legal specialist from Benchmark Reporting Agency.
Exhibit 31 E-mail from Julie Grand to Bill 321
9 Daly dated September 13, 2007, 9 The court reporter is Amanda McCredo in
Bates-stamped NHL2066067 through
10 association with Benchmark Reporting Agency.
10 069
11 Exhibit 32 E-mail from Julie Grand to Steve 322 11 Counsel, please introduce yourself.
Pellegrini dated November 8,
12 2007, Bates-stamped NHL2469756 12 MR. GRYGIEL: Good morning. Steve Grygiel
through 759
13 13 from Silverman Thompson in Baltimore for the
Exhibit 33 E-mail from Julie Grand to Steve 324
14 Pellegrini dated April 1, 2008, 14 plaintiffs.
Bates-stamped NHL1791667
15
15 MR. PENNY: Brian Penny from Goldman
Exhibit 34 E-mail from Bill Daly to Gary 326 16 Scarlato & Penny for the plaintiffs.
16 Bettman dated October 1, 2010,
Bates-stamped NHL2475474 17 MR. KEYTE: James Keyte for the NHL and
17
Exhibit 35 E-mail from Bill Daly to Gary 329 18 the witness.
18 Bettman dated October 2, 2010,
Bates-stamped NHL1723000 19 MR. LISAGAR: Matt Lisagar for the NHL.
19
Exhibit 36 E-mail from Jule Grand to Sean 332
20 MR. MARTINO: Matt Martino for the NHL.
20 MacLeod dated October 15, 2010, 21 THE VIDEOGRAPHER: Would the court
Bates-stamped NHL2466272 through
21 273 22 reporter please swear in the witness.
22 Exhibit 37 E-mail from Gary Bettman to Bill 335
Daly dated April 10, 2011, 23 JULIE G R A N D, the witness herein, after
23 Bates-stamped NHL0516458 through
459 24 having been first duly sworn by a Notary
24
25
25 Public of the State of New York, was
Page 7 Page 9
1 Exhibit 38 E-mail from Gerry Townend to 339 1 examined and testified as follows:
Julie Grand dated May 20, 2013,
2 Bates-stamped NHL2071340 through 2 EXAMINATION BY
1343
3 MR. GRYGIEL:
3
Exhibit 39 E-mail from Julie Grand to Gary 343 4 Q Good morning, Ms. Grand.
4 Meagher dated December 15, 2011,
Bates-stamped NHL1793860 5 A Good morning.
5 6 Q As you know, I'm Steve Grygiel
Exhibit 40 E-mail from Julie Grand to Beth 349
6 Chartoff dated January 21, 2013, 7 representing the plaintiffs. I know you're
Bates-stamped NHL1831930 through
7 931 8 familiar with the process, but nonetheless, we
8 Exhibit 41 Handwritten documents, 358 9 will go through the rules of the road.
Bates-stamped NHL2188574 through
9 590 10 I'm sure you understand, this only works
10 Exhibit 42 E-mail from Julie Grand to Ruben 361
Echemendia and Willem Meeuwisse
11 if we speak one at a time, right?
11 dated September 17, 2013, 12 A Yes.
Bates-stamped NHL2246968 through
12 996 13 Q Okay. And it's also important that your
13 Exhibit 43 Letter to Senator Blumenthal from 373
14 responses be verbal, since waves of the hand and
Commissioner Gary B. Bettman
14 dated July 22, 2016 15 nods of the head don't translate very well to the
15 Exhibit 44 E-mail from Julie Grand to Bill 375
Daly dated March 17, 2008, 16 record. Understood?
16 Bates-stamped NHL2060686 through 17 A Yes.
689
17 18 Q If you don't hear a question that I ask,
Exhibit 45 E-mail from Julie Grand to Gary 380
18 Bettman dated April 4, 2008, 19 let me know and I'll do my best to make it
Bates-stamped NHL2231587 through 20 audible for you, okay?
19 589
20 Exhibit 46 E-mail from Bill Daly to Gary 384 21 A Okay.
Bettman dated March 9, 2011,
21 Bates-stamped NHL1983530 through 22 Q And perhaps more likely, if you don't
531 23 understand a question that I ask, let me know,
22
23 24 and I'll do my best, if I can, to make it
24
25 intelligible to you, all right?
25
Page 10 Page 12
1 A Yes. 1 A Yes.
2 Q Are you taking any medications that would 2 Q Fully comfortable and ready to proceed?
3 impair your ability to testify fully and 3 A Yes.
4 truthfully today? 4 Q You're a graduate of the University of
5 A No. 5 Michigan?
6 Q Are you under any legal constraints that 6 A Yes.
7 would impair your ability to testify fully and 7 Q And your degree was in economics?
8 truthfully today? 8 A Yes.
9 A No. 9 Q What year did you get out?
10 Q Are you aware of any limitations on your 10 A '91.
11 ability to testify today? 11 Q At Michigan, did you study statistics?
12 A No. 12 A I took a class in statistics.
13 Q Have you taken depositions in the past? 13 Q Did you take any courses in
14 A Yes. 14 neurochemistry?
15 Q Approximately how many? 15 A No.
16 A One. 16 Q Did you take any courses in biochemistry?
17 Q And what kind of a case was that? 17 A No.
18 A It was the Derek Boogaard litigation. 18 Q Did you take any, what they call hard
19 Q And that was with Bill Gibbs? 19 science courses, such as oh, organic chemistry?
20 A Yes. 20 A No.
21 Q And have you been deposed before? 21 Q Did you do any premedical training at all?
22 A Yes. 22 A No.
23 Q How many times? 23 Q Did you take any courses in epidemiology?
24 A Oh, once. 24 A Not that I recall.
25 Q In what case was that? 25 Q When you graduated from Michigan, you went
Page 11 Page 13
1 A Now I'm wondering what your prior question 1 to UPenn?
2 was. My lawyers are looking at me like I 2 A I did.
3 answered it wrong. 3 Q Was there an interim there?
4 MR. KEYTE: No, no. 4 A No.
5 Q I thought that when you took a deposition 5 Q So you went straight to UPenn?
6 in the Boogaard case, you were deposed in the 6 A For law school, yes.
7 Boogaard case. 7 Q And you graduated, then, in 1994?
8 A I was deposed. 8 A Correct.
9 MR. KEYTE: I was wondering. 9 Q When you were at Penn, did you take any
10 A I didn't take a deposition. 10 courses in statistics?
11 MR. KEYTE: I was wondering if you took a 11 A No.
12 deposition in the Boogaard case. 12 Q When you were at Penn, did you take any
13 A No, I was -- my deposition was taken, yes, 13 courses in law in economics?
14 yes. 14 A Not that I recall.
15 MR. KEYTE: Yeah. 15 Q When you were at Penn, did you take any
16 Q Is that the only time you've been deposed? 16 courses in pharmaceutical regulation?
17 A Yes. 17 A No.
18 Q Okay. And have you ever taken -- 18 Q And after you left Penn, you came straight
19 A Now I have to listen to your questions 19 to Skadden?
20 more carefully. 20 A I did.
21 Q That's okay. Most people don't. 21 Q And you were working in the antitrust
22 Have you ever taken depositions yourself? 22 department?
23 A No. 23 A Yes.
24 Q You're familiar, then, with the rules of 24 Q And you were working with Shep Goldfein?
25 the road here today? 25 A Among other people.
Page 14 Page 16
1 Q Were you working with James Keyte at the 1 Q So it's fair to say you worked on a broad
2 time? 2 array of substance areas, correct?
3 A He was one of the people. 3 A Yes.
4 Q And you worked on the NFL case involving 4 Q In fact, fair to say that you have said in
5 the move of St. Louis Cardinals? 5 the past, no two days are really ever alike
6 A It was one of the things that I worked on. 6 unless you work on the collective bargaining
7 Q And you got to know Shep and James pretty 7 agreement for weeks at a time?
8 well in that process? 8 A And I don't think those days were probably
9 A In addition to other people. 9 alike then either.
10 Q And Bill Daly was already at the NHL at 10 Q Lots of different demands on your time?
11 that time? 11 A Yes.
12 A Bill Daly left Skadden in '97. 12 Q When you came to the NHL in 1999, your
13 Q And after he went to the NHL after you had 13 title was deputy general counsel, wasn't it?
14 been at Skadden, he called you over, correct? 14 A Yes.
15 A I went to the NHL in '99. 15 Q And in 2002, you added the title of vice
16 Q When you got to the NHL in 1999, had you 16 president?
17 done any work for the NHL as a lawyer at Skadden? 17 A I did. I don't recall if that was the
18 A I had. 18 year, but that sounds about right.
19 Q What work was that? 19 Q And sometime after that, you became senior
20 A Let me see if I can specifically remember. 20 vice president and deputy general counsel,
21 There was a tampering matter that I had 21 correct?
22 worked on, a tampering investigation. 22 A Correct.
23 Q And by that you mean of one club of 23 Q Do you have any other titles at the NHL?
24 another player's clubs -- or another player's -- 24 A No.
25 another club's players? 25 Q Now, when you came to the NHL in 1999, you
Page 15 Page 17
1 A Yes. 1 were aware that the initial phase of the
2 Q Anything else? 2 concussion study was underway, correct?
3 A I'm not sure if I have a recollection. 3 A Yes.
4 Q When you got to the NHL in 1999, what was 4 Q That it had begun in 1997?
5 your scope of duties? 5 A Yes.
6 A When I started my job? 6 Q And that was under the stewardship, among
7 Q Yeah. 7 others, of Dr. Chip Burke?
8 A I was working on collective bargaining 8 A Yes.
9 matters. So providing advice to our clubs and to 9 Q When you came to the League in 1999, were
10 the League on the collective bargaining 10 you given a specific charge of overseeing that
11 agreement. Working on administration of the 11 project from the NHL's perspective?
12 collective bargaining agreement, working with the 12 (Telephonic interruption.)
13 Players' Association on collective bargaining 13 MR. KEYTE: Object as to form.
14 matters, whether in the context of discussing new 14 A I don't think I would describe that from
15 issues or addressing issues under the collective 15 the outset. Not in my sole -- you know, that
16 bargaining agreement. Working a number of those 16 wasn't my -- I wasn't the only person who was
17 matters, included health and safety-related 17 working on that from a league perspective. There
18 matters. Working on litigation that arose. And 18 were others who I worked on it with at a league
19 working on other matters for the commissioner at 19 level.
20 his request, whether that's club disputes or 20 Q And who were those people?
21 issues between clubs. There was a broad array 21 A When I first started, Kate Jones was
22 of, of, of matters that I was working on. Other 22 there, I believe, and she also, at a league
23 things that would come up with other departments 23 level, was kind of overseeing and working with
24 in the League that I would work on and give 24 the physicians on the head injury project, I
25 advice to. 25 think it was called at the time. And Bill Daly
Page 18 Page 20
1 was also actively involved in overseeing that 1
2 project. And I would also say that Brian O'Neil, 2
3 also, throughout time, has also been actively 3
4 engaged with our team physicians and the injury 4
5 committees and Team Physicians Society with the 5
6 projects that they've done. Those are probably 6
7 the primary people. 7
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1 1 MR. KEYTE: I've never said it that way,
2 2 so...
3 3 Q And you've spoken with Winne Meeuwisse
4 4 about player brain safety?
5 5 A I have.
6 6 Q And you've spent a fair bit of time
7 7 talking with him about that issue, haven't you?
8 8 A I have.
9 9 Q And you've spoken, of course, with John
10 10 Rizos of the PA, correct?
11 11 A I have.
12 12 Q And you've spoken with him about brain
13 13 safety on many occasions, right?
14 14 A I have.
15 15 Q And you have no reason to doubt that
16 16 Dr. Rizos takes player brain safety very
17 17 seriously, right?
18 18 A No reason to.
19 19 Q Okay. And of course, you've spoken with
20 . 20 Dave Dryden about it?
21 21 A I have.
22 22 Q And you have spoken with other, with other
23 23 members of what was first called the injury
24 24 analysis panel, correct?
25 25 A Correct.
Page 23 Page 25
1 1 Q And you've spoken with members of the
2 2 health management panel, right?
3 3 A Correct.
4 4 Q And with members of the Concussion Working
5 5 Group, correct?
6 6 A Correct.
7 7 Q And the joint health and safety committee,
8 8 right?
9 9 A Correct.
10 10 Q There have been a number of working groups
11 11 that have looked at the issue of player brain
12 12 safety over the years, right?
13 13 A Absolutely.
14 Now, during the course of your work at the 14
15 NHL, you spent a fair bit of time talking with 15
16 people about player brain safety, haven't you? 16
17 A I have. 17
18 Q And you've spent a fair bit of time 18
19 talking to Ruben Echemendia about it? 19
20 A I have. I would say his name differently, 20
21 but I have. 21
22 Q Echemendia? 22
23 A Echemendia. 23
24 Q Echemendia. I apologize. I'll get that 24
25 wrong more than once today. 25
Page 26 Page 28
1 1 Q Okay. And you have drafted presentations
2 2 for the Board of Governors of the National Hockey
3 3 League concerning player brain safety, correct?
4 4 A Correct. And for the general managers.
5 5 Q I was just going to say. And with the
6 6 general managers, right?
7 7 A Correct.
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12 Q And in working on that issue, you've 12
13 worked with other PA personnel than the ones I've 13
14 identified, right? 14
15 A Correct. 15
16 Q You've worked with Ian Pulver? 16
17 A Correct. 17
18 Q And you've worked with Paul Kelly? 18
19 A Yes. 19
20 Q You've worked with Maria Dennis? 20
21 A Yes. 21
22 Q You don't have any reason to doubt that 22
23 any of those people don't take player brain 23
24 safety very seriously? 24
25 A I do not. 25
Page 30 Page 32
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13 13 Q Fair to say you've been the NHL executive
14 14 office's point person on the question of player
15 15 brain safety, as I've described it?
16 16 MR. KEYTE: Object as to form.
17 17 A So, you're using a term "brain safety."
18 18 I'll just say, that it isn't a term that I
19 19 generally use to describe what I do. And so
20 20 maybe that's what I'm a little uncomfortable
21 21 with.
22 22 Q If I use "concussions," does that help?
23 23 A Yes. We use the term "the concussion
24 24 program."
25 25 Q Okay.
Page 31 Page 33
1 1 A Okay.
2 2 Q Fair to say, fair to say that, fair to say
3 3 that you've been the NHL executive's office point
4 4 person on the concussion program?
5 5 A Yes.
6 6 Q If fact, no one in the NHL executive
7 7 office has spent as much time on that issue as
8 8 you, correct?
9 9 A That's probably a fair statement.
10 10 Q Now, in terms of looking at the concussion
11 11 program, the concussion program has looked at a
12 12 number of ways of helping to improve players'
13 13 head safety, correct?
14 14 MR. KEYTE: Objection. Overbroad.
15 15 A A number of ways -- repeat the question.
16 16 Q Sure. The concussion program, to use your
17 17 words, has looked at a number of different ways
18 18 of helping to promote players' head safety and
19 19 brain safety, correct?
20 20 MR. KEYTE: Objection. Foundation.
21 21 A I'm not, I'm not sure that's a fair
22 22 statement.
23 23 Q Let me break it up.
24 24 One of the areas the concussion program
25 25 has looked at is playing equipment, correct?
Page 34 Page 36
1 A Not really, no. 1 Q Sure. One of the things you were looking
2 Q You didn't discuss that with Dave Dryden? 2 at is getting information.
3 A So -- but Dave Dryden was the injury 3 So, for example, the playing rules, if
4 analysis program -- 4 they need to be, can be modified to promote
5 Q I know. 5 player safety?
6 A -- so I wouldn't call Dave Dryden the 6 A I'm sorry, your first statement dealt with
7 concussion program. I think it's a question of 7 education, and your second statement just dealt
8 what group is looking at what area. And so I'm 8 with rules. So, I'm not sure you're repeating --
9 not, I'm not trying to, like -- 9 could you just read back the -- or can you --
10 Q Haven't you participated in discussions 10 Q Scratch that.
11 about whether or not shoulder pads should have 11 MR. KEYTE: Yeah, there's, like, two
12 certain padding on them to help reduce the impact 12 questions at the same time.
13 on head hits? 13 Q I'm not interested.
14 A I have, and that's in the context of the 14 One of the areas you've looked at is the
15 protective equipment subcommittee. 15 question of studying retired players, correct?
16 Q Okay. So, equipment has been one area 16 A Who's the "you"?
17 that the concussion program has looked at? 17 Q You.
18 MR. KEYTE: Objection. Foundation. 18 A Oh, me personally?
19 A Again, again, you're calling the 19 Q Yes, you. That's why I said "you."
20 concussion program. So, when I, when I refer to 20 A Okay.
21 the concussion program, I refer to the concussion 21 MR. KEYTE: I'll object on foundation
22 subcommittee. 22 grounds.
23 Q Okay. 23 A It had -- yes.
24 A Okay. And the concussion subcommittee is, 24 Q And you have discussed that with
25 is a group that we have of -- a specific group, 25 Dr. Echemendia?
Page 35 Page 37
1 okay, and we can go through, over time, like, who 1 A Correct.
2 was a part of that group. 2 Q And you have discussed that with
3 We've had other groups that are also 3 Dr. Meeuwisse, correct?
4 league, NHLPA, doctors, trainers, but other 4 A I mean, the concussion subcommittee. So,
5 groups that not the concussion subcommittee that 5 I think in the context of the concussion
6 have looked at other aspects of this, including 6 subcommittee. And the health management panel.
7 equipment, environment, rules, and other 7 Q It's been something you've looked at from
8 components of it. But those, to me, they're 8 time to time, correct?
9 getting at the concussion -- the topic of 9 A Correct.
10 concussions, but those are other groups that 10 Q Have you ever spoken, yourself,
11 aren't the concussion subcommittee. 11 personally, with any member of the NHL Alumni
12 Q You said equipment, rules. 12 Association about such a study?
13 Isn't another area that's been looked at, 13 A Not that I recall.
14 not by necessarily just the concussion 14 Q Have you ever spoken personally, yourself,
15 subcommittee, the question of the playing 15 with any member of the NHLPA's executive
16 environment, the boards and glass configuration? 16 committee, apart from Rizos and doctors, about
17 A Correct. 17 such a study?
18 Q And another area has been player 18 A I don't know if I know who is on the NHLPA
19 education, correct? 19 executive committee.
20 A Correct. 20 Q Have you ever spoken with Ian Pulver about
21 Q And the idea has been to develop 21 it?
22 information so that you can better make choices 22 MR. KEYTE: The "it" is the potential of
23 concerning those areas? 23 the --
24 MR. KEYTE: Objection. Foundation. 24 MR. GRYGIEL: Retiree study.
25 A I'm sorry, say your statement again. 25 A Well, I mean, we talked about it at a
Page 38 Page 40
1 health management panel meeting, and I don't 1 MR. KEYTE: Again. Objection.
2 remember precisely who was at that meeting. I 2 Foundation.
3 don't, I'd have to look at the minutes of that 3 Steve -- can you speak a little bit more
4 meeting to see who from the union was at that 4 slowly, Steve?
5 meeting. 5 MR. GRYGIEL: Okay.
6 Q Wouldn't a retiree study help to inform 6 MR. KEYTE: Because I actually can't
7 decisions, for example, about the playing rules? 7 follow your questions when you speak that fast.
8 MR. KEYTE: Objection. Overbroad. 8 MR. GRYGIEL: As quick as you are, I bet
9 A It could. I think there is -- 9 you can.
10 Q Haven't you, in fact, said it would? 10 A I would appreciate it, too, if you could
11 A Can I finish answering my question, 11 speak a little slower.
12 please? 12 Q I'll try.
13 Q Sure. I'm sorry. 13 A Thank you.
14 A It's okay. 14 I think that from -- again, from the, from
15 I think that it, it could. I think 15 the beginning of our program, we knew that
16 there's so many questions as to what it is you 16 players had, who had a risk of having long-term
17 study, how you design a study, what precisely 17 neurocognitive effects from post-concussion
18 your -- the data you look at and the answers 18 syndrome and they may not recover or -- you know,
19 you're trying to -- the questions you're trying 19 short-term or maybe a long-term, from those
20 to answer, and depending on the information you 20 symptoms. And, and that we provided education on
21 get, you know, what, what information you get. 21 to our players.
22 And then you look at that information, and 22 Something kind of more than that, to me,
23 it could be that, depending on that information, 23 sounds like what you're suggesting or asking
24 what decisions you want to make -- can I finish, 24 about, and, and I don't think that was really a
25 please? 25 question that was in, in our minds. It wasn't
Page 39 Page 41
1 Q I hadn't said anything. 1 anything that there was scientific evidence for,
2 A You looked like you were about to. 2 that there was a reason to ask the question of
3 MR. KEYTE: Go ahead. Finish your answer. 3 from a scientific basis. There wasn't any
4 Q Have you been talking to my wife? 4 players it had happened to. It hadn't really
5 A Depending on the information that you get, 5 come on to the horizon, I guess I would say,
6 there may be decisions that you want to make 6 until some point in time. No one had asked the
7 based on it, which, which could, which could be 7 question.
8 playing rule decisions. Obviously, it would 8 Q Now, Dr. Echemendia, from time to time,
9 depend on what information you get. 9 discussed a retiree study with you, correct?
10 Q You've always personally thought it would 10 A He did.
11 be important to know whether retirees were at 11 Q And, in fact, he raised the issue with you
12 greater risk, for example, suffering 12 more than once, didn't he?
13 neurocognitive impairments than the general 13 A He did.
14 population might be, correct? 14 Q And you thought about his questions about
15 MR. KEYTE: Objection. Overbroad. 15 that issue, didn't you?
16 A Have I always thought that? 16 MR. KEYTE: At what point in -- I'm sorry,
17 Q Yes. Always since you've joined the 17 for your question, at what point in time?
18 National Hockey League. 18 MR. GRYGIEL: Any time.
19 A No, I don't, I don't think -- I don't know 19 Q You weren't confused by my question, were
20 that that's a fair statement. 20 you?
21 Q So there's been times during your work for 21 A No, I'm fine.
22 the National Hockey League that you didn't think 22 Q Yeah, thank you.
23 determining whether or not retirees were at 23 A No, he, he raised it. He was, he was
24 greater risk for neurocognitive impairment was an 24 interested. I think he thought it was something
25 important issue? 25 that would be interesting to study.
Page 42 Page 44
1 Q And he also consulted, you knew, to the 1 MR. GRYGIEL: February 11, 2008.
2 NHL on their study of retirees. 2 MR. KEYTE: Okay.
3 A The NHL had, I think in 2008, had had a 3
4 number of players who had been -- who had had -- 4
5 postmortem been identified to have CTE. 5
6 And they had decided to, I think, have two 6
7 separate studies that they had done. One was 7
8 kind of a snapshot -- a survey study, and then 8
9 they decided to design one other study. And they 9
10 asked Ruben for his views on it. 10
11 And I think, you know, that kind of got 11
12 him thinking that this could be interesting, and 12
13 that was when he first reached out to me and 13
14 said, you know, "They did it this way. And I was 14
15 thinking it could be interesting for, you know, 15
16 us -- if we were doing it, we would could do it 16
17 that way." 17
18 Q He didn't just think it was an interesting 18
19 issue. He thought it was an important issue, 19
20 didn't he? 20
21 A He said it could be interesting -- 21
22 MR. KEYTE: Let me just -- 22
23 A -- and important. 23
24 MR. KEYTE: Let me just put in my -- 24
25 object as to form. 25
Page 43 Page 45
1 Q I'm going to show you, Ms. Grand, what we 1
2 have marked as Exhibit Number 1. 2
3 (E-mail from Julie Grand to Bill 3
4 Daly dated February 11, 2008, 4
5 Bates-stamped NHL 1971101 was 5
6 marked as Exhibit 1 for 6
7 identification, as of this 7
8 date.) 8
9 Q You will see this is a one-page document. 9
10 At the top, the date is February 11, 2008. And 10
11 we have an e-mail chain here involving you, Bill 11
12 Daly, and Dr. Echemendia, correct? 12
13 A Yes. The bottom e-mail is from Ruben to 13
14 me, and the top e-mail is from me to Bill. 14
15 Q In your e-mail to Mr. Daly, you say that 15
16 you're "not sure we want to start focusing on a 16
17 retired player study at this point. Your 17
18 thoughts." 18
19 First, why were you not sure that it made 19
20 sense to start focusing on a retired player study 20
21 at that point? 21
22 MR. KEYTE: Steve, could you just put the 22
23 date of the e-mail? 23
24 MR. GRYGIEL: I did. 24
25 MR. KEYTE: Did you? I'm sorry. 25
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20 20 Q I'm going to show you what we're marking
21 21 as Exhibit 2, because you said that the NHLPA
22 22 objected to a retiree study because of the
23 23 employability concern.
24 24 A Yes.
25 25 Q I'd like to help, see if you could help
Page 54 Page 56
1 clear this up for me. 1 MR. KEYTE: Objection. Foundation.
2 (Document entitled CWG Meeting 2 A The union -- I don't remember what the
3 Summary: May 1, 2012 3 specific -- whether you're studying current
4 Bates-stamped NHL2275298 through 4 players or retired players, any study that's
5 303 was marked as Exhibit 2 for 5 designed that has the same conclusion is going to
6 identification, as of this 6 have the same effect on current players. So the
7 date.) 7 union's going to have the same opposition to a
8 Q If you look at Exhibit Number 2, you will 8 study, whether it's -- whether your, whether your
9 see it is a CWG meeting summary, May 1, 2012, 9 data set is it for current players or retired
10 correct? 10 players, because it's going to, ultimately, the
11 A Yes. 11 impact is going to be on current players who
12 Q And you will see that you were shown as an 12 retire of employability.
13 attendee, right? 13 Q So, is it your testimony that this
14 A Yes. 14 subparagraph B, the proposed study here, deals
15 Q And this is a two-page document, right? 15 with retired players?
16 Well, it's more than two pages. It's a 16 MR. KEYTE: Objection. Foundation.
17 three-page document. 17 A Well, I can read the whole thing, if you'd
18 A No. I don't know. 18 like, but --
19 Q Six pages. 19 Q If you need to --
20 A It looks like a five-page document. 20 A I'm not sure if makes a difference.
21 Q Six-page document. 21 Q So what you're saying is, the PA would
22 A One, two -- 22 oppose any study that would show long term,
23 Q Six pages? 23 neurocognitive impairments in players whether
24 A One, two, three, four -- a six-page 24 they're retired or current?
25 document. 25 MR. KEYTE: Objection. Mischaracterizes
Page 55 Page 57
1 Q And the reason I was confused in my 1 the testimony.
2 pagination is because, if you look at the top of 2 MR. GRYGIEL: I don't think it does at
3 the second page, Ms. Grand -- 3 all.
4 A Yeah. 4 MR. KEYTE: Well, it completely does.
5 Q -- you'll see there is a study proposal 5 A I --
6 under heading B, correct? 6 MR. GRYGIEL: The facts are what they are.
7 A Yes. 7 MR. KEYTE: Would you want to have her
8 Q "Is self-reported concussion history 8 answer read back?
9 associated with lingering cognitive deficits in 9 MR. GRYGIEL: No. I don't have the time.
10 the NHL," correct? 10 MR. KEYTE: Okay. All right. It's a
11 A Yes. 11 different question.
12 Q And if you look down to the middle 12 A I believe that any study that we did on
13 paragraph and the paragraphs that follow that, 13 long term cognitive impairment, we would need to
14 you will see there is an expression of concern by 14 do with the union. So, whether that's on current
15 the PA about stigma and employability for 15 players, whether that's on retired players, I
16 players, correct? 16 don't, I don't think who the group is would make
17 Take a moment. 17 a difference. We've always dealt jointly with
18 A Where did -- what paragraph are you 18 the union on, collaboratively on every issue
19 referring to? 19 relating to the concussion program. And I think
20 MR. KEYTE: Third. 20 the effect of -- the practical effect of the
21 Q Sure. If you look in the third full 21 results, the union -- based on the, the concerns
22 paragraph that begins with the word "also". 22 they expressed, they would have a concern that
23 A Oh, let me see. Yes. 23 the practical effect of the results would affect
24 Q Doesn't this subparagraph B deal with 24 current players, regardless of who your study
25 current players, not retired players? 25 group was.
Page 58 Page 60
1 Q Can we agree that the document we're 1 Dr. Meeuwisse to Dr. Echemendia, carbon-ing you.
2 looking at here doesn't specifically refer to 2 And the date of the e-mail is April 1, 2008.
3 retiree player studies? 3 Attached to this e-mail is a -- three,
4 A I'd have to go through and read the whole 4 separate pages of handwritten notes.
5 thing. 5 Do you see those there?
6 Q Go ahead. 6 A I do --
7 A Which I'm fine doing. 7 Q And the notes are dated --
8 Q Go ahead. 8 A But it's more than three pages, again, I
9 A (Reviews document.) Yeah, I believe this 9 would say.
10 was on current players. 10 Q Well, you're looking at the backs of the
11 Q And this doesn't refresh your recollection 11 pages. Right. Apparently my arithmetic in
12 of any discussion that PA had said, and we'll 12 counting pages isn't very good.
13 have the same objection if it's about retired 13 The handwritten notes are dated 4/1/08,
14 players, too? 14 correct?
15 A You know, our, our, our discussions with 15 A Yes.
16 the players over time, I think starting in 2008 16 Q And that's your handwriting?
17 and going through 2014, about really how to 17 A It is.
18 approach this, really evolved, over time, of 18 Q And these are notes you took during the
19 really what we were talking about, who we were 19 conference call that's recorded on the first
20 talking about. At some point, it was kind of a 20 page -- or reflected on the first page?
21 retired player study. Sometimes it was a long 21 A I mean, it looks like it was a concussions
22 term study. It was a longitudinal study. Kind 22 working group, and I don't know if it was a call
23 of who the study group was, what precisely we 23 or a meeting. I guess this Re line is a
24 were studying, what we were studying it for. I 24 conference call.
25 would say, really -- I don't know if it was ever 25 Q And the first paragraph refers to a call?
Page 59 Page 61
1 precisely to find, it was more of amorphous 1 A Some convening of a Concussion Working
2 concept that kind of changed very fluidly over 2 Group.
3 those points in time, with people just having a 3 Q And if you look at Number 5, under Future
4 general interest in us further exploring 4 Directions, it says, "Retired Players, hyphen, NP
5 concepts. And ultimately that was the idea of 5 Issues Over Time," correct?
6 putting together a task group, to really try to 6 A Yes.
7 define it further. 7 Q And that reflects that the subject was
8 But I do think that the union ultimately 8 discussed with the PA, correct?
9 had concerns about the results of anything and 9 A Yes.
10 how it affected current players. And really our 10 Q The PA representatives?
11 way to address that was to say, "Let's just come 11 A Uh-huh.
12 up with a group to form a proposal on how we 12 MR. KEYTE: Again, objection. Foundation.
13 would study this." 13 I'm not sure which represent --
14 And the union got comfortable with that 14 Q You don't have any doubt that this is an
15 concept. And then we, you know, that's kind 15 accurate reflection of the call, do you?
16 of -- we got their buy-in on that. 16 A Well, let me just look here at both of
17 Q Let me show you what we are marking as 17 these.
18 Exhibit Number 3. 18 So, we have Concussion Working Group
19 (E-mail from Ruben Echemendia to 19 notes. We have Paul Comper, John Rizos, Ruben,
20 Willem Meeuwisse Bates-stamped 20 and so you get to my notes, and it looks like, at
21 NHL1352051 through 057 was 21 the end, Ruben says -- you kind of have two
22 marked as Exhibit 3 for 22 different versions of, I guess, people's
23 identification, as of this 23 summaries of meeting. And so my handwritten
24 date.) 24 notes are my notes of what happened. And then it
25 Q It begins with a cover page e-mail from 25 looks like Winne also kind of summarized what
Page 62 Page 64
1 happened. 1 talked about the fact that you would need to
2 Q Let's turn to your notes in the page that 2 appropriately control -- have an appropriate
3 ends with the Bates numbers 57. I think you've 3 control group and the complications of that.
4 got it right in your hand, right? 4 And then there was various meetings when
5 A Yes, uh-huh. 5 we started to actually talk about what would it
6 Q And you see, on the left-hand side of the 6 look like. And some proposals were drafted and,
7 page, the words "Future Directions," right? 7 and you can fast forward to what it looked like
8 A Uh-huh. 8 when we started to actually put proposals on the
9 Q And you see, next to the word "Ruben --" 9 paper. There was, there was another meeting, I
10 A Yes. 10 think, in 2010, I think, where Rizos and Comper
11 Q -- quote, Retired Players Longitudinally 11 and maybe Ruben were supposed to sit down and
12 Over Time, close quote, correct? 12 formulate what our proposals were.
13 A Yes. 13 So yes, I mean, we had lots of discussions
14 Q And underneath that we, have got two 14 about it, and people were generally thought, like
15 bullet entries, don't we? 15 this is, this is a good idea, let's talk about
16 A I wouldn't describe them that way, but 16 it. And then kind of starting to talk about it,
17 yes. 17 it evolved over time. And definitely went in a
18 Q "Neurocognitive Impairment, hyphen, Over 18 lot different directions.
19 Time," is one. 19 Q Well, I'm confused, because as of May 1,
20 A Yes. 20 2012, you told me that the PA was opposed to any
21 Q "Improved Diagnosis, hyphen" -- or 21 study of retirees or currents players that would
22 semicolon or comma -- "Better Awareness," 22 show neurocognitive impairments, and here we show
23 correct? 23 a document where they're saying the opposite.
24 A That's what it says. 24 What changed?
25 Q The and next line is "Rizos," right? 25 A Well, that's what I'm, that's what I'm
Page 63 Page 65
1 A Yes. 1 saying. Is so, we had some, I think, very
2 Q And that refers to Dr. John Rizos, right? 2 high-level conceptual discussion. You know --
3 A Yes. 3 you see -- this is the discussion, right?
4 Q And the words next to his name say, 4 Retired player longitudinally over time, that
5 "Reasonable, Helpful," correct? 5 sounds, that sounds reasonable. That would be a
6 A Correct. 6 good thing. And then let's, let's start to talk
7 Q And underneath that, there's the words 7 about it more. What does it look like? Again,
8 "Paul C.," right? 8 is it retired players? Is it, is it current
9 A Yes. 9 players? Is it -- I think the devil's in the
10 Q And that refers to Paul Comper, doesn't 10 details. Fleshing it out. What are the
11 it? 11 implications? Fleshing it out. Looking, you
12 A Correct. 12 know, looking at what is it precisely we're
13 Q And next to that, the handwriting says, 13 talking about? And that, that's the process we
14 "Would be a good thing," correct? 14 went there, as you can probably trail it through
15 A Correct. 15 the meetings and the proposals and, and you can
16 Q So here, isn't it true that what Dr. Rizos 16 follow the conversations.
17 and Paul Comper were saying that a retired 17 Q So, the employability concern, you're
18 players study, done longitudinally over time 18 saying, arose later when the details became more
19 would be a good thing? 19 apparent?
20 A That, that was the initial conversation 20 A That was the course of the conversation.
21 that we had. As we said, I mean, I don't know 21 Q So with this initial discussion, where
22 how many of these we're going to go through, but 22 Rizos thought it was a good idea, he never said,
23 we had, we did, we did have conversations and 23 "Gee, wiz, employability could be a problem"?
24 this was brought in up in 2008. We brought it up 24 A I, I don't recall that being raised at
25 again at the health management panel in 2009. We 25 this time, but, I mean...
Page 66 Page 68
1 Q Did Rizos ever tell you why he thought 1
2 employability was an issue in 2012 when it was 2
3 not in 2008? 3
4 A We, we, we -- no. 4
5 Q Did Comper ever give you such information? 5
6 MR. KEYTE: I'm sorry, in 2008? 6
7 MR. GRYGIEL: No, at any time. 7
8 Q About why employability became an issue 8
9 when it was not in 2008 when it was apparently an 9
10 issue, you said, in 2012? 10
11 MR. KEYTE: Again, objection. Foundation. 11
12 You're mischaracterizing her testimony. 12
13 A I don't know if I recall Comper expressing 13
14 that. I think it was a -- it was issues that 14
15 John Rizos raised and Maria raised. 15
16 (Concussion - retired player 16
17 study from Julie Grand to Bill 17
18 Daly dated March 13, 2008, 18
19 Bates-stamped NHL2267898 was 19
20 marked as Exhibit 4 for 20
21 identification, as of this 21
22 date.) 22
23 THE WITNESS: May I get some water, 23
24 please? 24
25 MR. GRYGIEL: Absolutely. 25
Page 67 Page 69
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14 14 Q And as of this date, 2008, no NHL player
15 15 had been diagnosed after death with CTE, correct?
16 16 A I think -- yes, that's correct.
17 17 Q It wasn't until 2009 that I think it was
18 18 Reggie Fleming died, and that was the first?
19 19 MR. KEYTE: Late -- do you want the
20 20 specific date or -- late December.
21 21 MR. GRYGIEL: Reggie Fleming, July 11,
22 22 2009.
23 23 MR. KEYTE: No, that's incorrect.
24 24 MR. PENNY: Steve is talking about the
25 25 date he died.
Page 74 Page 76
1 MR. KEYTE: No, when he died. 1 MR. KEYTE: Is this a good time for a --
2 MR. GRYGIEL: Yeah. 2 because we've been past that hour. Is it --
3 MR. KEYTE: Oh, I thought you meant -- the 3 you're going on to another document?
4 CTE diagnosis -- 4 MR. GRYGIEL: Sure.
5 MR. GRYGIEL: No, no, no. 5 MR. KEYTE: Why don't we take five
6 MR. KEYTE: -- was in your question. 6 minutes?
7 MR. GRYGIEL: No. 7 MR. GRYGIEL: That's fine. Sure.
8 Q July 11, 2009. 8 THE VIDEOGRAPHER: The time is 10:14.
9 A Oh. 9 We're going off the record.
10 Q In other words, my question simply was -- 10 (Recess taken.)
11 A I don't recall his, his date of death. 11 THE VIDEOGRAPHER: The time is 10:28.
12 Q But at the time you were having these 12 We're back on the record.
13 discussions concerning this retiree study, no NHL 13 Q Have you ever spoken with Dr. Daniel Perl?
14 player had been -- died and been diagnosed with 14 A It doesn't ring a bell.
15 CTE? 15 Q If I identify him as the director of
16 A I mean, to, to us, kind of the, the, the, 16 neuropathology at Mount Sinai School of Medicine,
17 the date is the diagnosis of CTE, which I think 17 New York, does that refresh your memory at all?
18 was December, late December -- now all my dates 18 A It doesn't ring a bell, but I'm sure you
19 are getting jumped in my head -- 2009, yeah. 19 can refresh my recollection with a document.
20 MR. PENNY: You got it. 20
21 THE WITNESS: Yeah. 21
22 A So, yes, you're correct. 22
23 23
24 24
25 25
Page 75 Page 77
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10 10
11 11 Q Didn't Dr. Echemendia tell you that one of
12 12 the reasons for doing a long-term study of
13 13 retirees was because a good database already
14 14 existed in terms of the NP testing for players
15 15 who had retired?
16 16 A Ruben said that, if we did -- we kept
17 17 changing the terminology -- but a long-term study
18 18 or a retired player study, he contemplated us
19 19 using that database.
20 20 Q Were you privy to any discussions between
21 21 Mr. Daly and Mr. Pulver concerning a long-term
22 22 study of retiree cognitive health?
23 23 MR. KEYTE: Object to foundation.
24 24 A I think that it came up -- the topic came
25 25 up at a health management panel meeting, maybe in
Page 78 Page 80
1 early 2009, that Bill and Ian and maybe, like, 1 reflecting Bill being crudely dismissive. Again,
2 ten other people were at, if that's what you're 2 I think it was an evolving discussion over time,
3 referring to. 3 but I certainly don't recall Bill being
4 Q It is. 4 dismissive.
5 A Okay. 5 Q Do you have any understanding why
6 Q And do you remember Mr. Daly was, quote, 6 Mr. Pulver would use those words, "crudely
7 crudely dismissive, close quote, of the idea of 7 dismissive"?
8 such a study? 8 MR. KEYTE: Objection. Foundation.
9 A Well, I've seen the document that you 9 A No.
10 marked, and so I saw Ian's -- 10 Q Now, it says here that the head of the
11 Q Exhibit Number 5 is now in front of you. 11 concussion group indicated that plans for such a
12 (E-mail from Ian Penny to Andrew 12 study were underway.
13 Wolfe and others dated January 13 That was Dr. Echemendia, correct?
14 28, 2009, Bates-stamped 14 A 2009, health management panel -- well, I
15 NHLPA_0001308 to 10 was marked 15 don't remember at that time if -- yes, that would
16 as Exhibit 5 for identification, 16 have been Ruben, uh-huh.
17 as of this date.) 17 At some point Paul and Ruben became
18 A I've seen Ian's characterization of it as 18 co-chairs, but I think that would have been after
19 that. I don't -- you know, when I saw this, I 19 2012. So, this is probably just referring to
20 don't remember that being Bill's reaction to it, 20 Ruben.
21 but -- I don't remember that being Bill's 21 Q So, it sounded like Dr. Echemendia and
22 reaction to it. 22 Mr. Daly were not on the same page concerning the
23 Q Simply for identification, this is an 23 value of a long-term retiree study.
24 e-mail from Mr. penny to a number of folks, and 24 MR. KEYTE: Objection. Foundation.
25 the date is January 28, 2009, correct? 25 A As I've said, you know, I, Ruben thought a
Page 79 Page 81
1 A I'm sorry, say it again. 1 study would be interesting. He, he, he brought
2 Q Sure. I'm just identifying it. This is a 2 it up to us on, you know, a couple of occasions,
3 January 28, 2009 e-mail from Ian Penny to a 3 and we discussed it at our, at our meetings on
4 number of people. 4 several occasions, and our, our minutes and our
5 A Correct. 5 notes reflect that.
6 Q Okay. Now, this is the meeting you were 6 Q You don't have any doubt that at this
7 referring to, right, just a moment ago? 7 meeting that is referred to in this e-mail that
8 A The health management panel meeting. 8 Dr. Daly did oppose the idea, whether or not he
9 Q Right. And it's your testimony that 9 was crudely dismissive?
10 Mr. Daly was not, quote, crudely dismissive, 10 A I'm sorry, can say that again?
11 close quote, of the idea of a long-term study of 11 Q You don't have any doubt at this meeting
12 concussed hockey players? 12 Mr. Daly opposed the idea of the study, whether
13 A I don't remember Bill being crudely 13 or not he was, quote, crudely dismissive?
14 dismissive. 14 MR. KEYTE: Objection. Foundation.
15 I also have notes from that meeting, which 15 A I don't know whether or not he opposed the
16 you probably have. And I don't have a specific 16 idea.
17 recollection of the discussion at that meeting. 17
18 You know, I think, my notes from that meeting, I 18
19 think, show that we, we discussed it, and I think 19
20 it said that there was issues with -- you know, 20
21 I'm kind of losing my track of the timing -- 21
22 either people said we should further look at it, 22
23 or maybe there was issues with control group that 23
24 we needed to look at. 24
25 And so I don't, I don't remember my notes 25
Page 82 Page 84
1 1 land. What I want to understand is, at any time,
2 2 to your memory, did anyone at the PA ever say,
3 3 quote, Under no circumstances will the PA agree
4 4 to a study of retirees' neurocognitive health,
5 5 close quote?
6 6 MR. KEYTE: Objection. Foundation.
7 7 A We didn't have conversations that were
8 8 black and white conversations like that. So
9 9 your, your question is not a question that can be
10 10 answered. And I know you're looking for a yes or
11 11 a no.
12 12 Q I am.
13 13 A I know. But, but that's not how the
14 14 conversations occurred.
15 15 Q Did any member of the PA, at any time, to
16 16 your knowledge, say the PA, under no
17 17 circumstances, could agree, because of
18 18 employability concerns, to a study of the
19 19 neurocognitive health of current players?
20 20 A Can you repeat your question, please?
21 Q Would it be accurate to say, at any time, 21 Q Sure. Did any member of the PA, at any
22 that the Players' Association has expressly 22 time, ever say words to the effect that the PA
23 refused any study of retirees' long term mental 23 could never agree to a study of decreases in
24 cognitive health? 24 neurocognitive health of current players, because
25 MR. KEYTE: Objection. Asked and 25 of employability concerns?
Page 83 Page 85
1 answered. 1 A The PA responded to specific proposals
2 A We, we already went through this. You 2 that were presented to them. That was the
3 know, as I said, we've discussed this at specific 3 context for the conversations.
4 meetings where there were specific proposals on 4 We left that meeting in May, and we came
5 the table. But we discussed it in the context 5 back at our follow-up meeting in, I think, June
6 of, I told you, a number of meetings over a 6 and continued those conversations where they
7 number of years, where we're talking about 7 said, "We're going to -- we need to get more
8 different things at different meetings. And some 8 feedback from the players."
9 of those were a general concept of a retired 9 And then we continued those conversations,
10 player study. And some of those were, were not a 10 and then we went from there to say, "What
11 retired player study. They were just a long-term 11 direction can we take this in?" And then, the
12 study, right? And it was, it was a really 12 direction we took it in was, let's -- you know,
13 different -- they were different things, and I'm 13 we, we -- we're not supporting this (indicating),
14 not sure if they were even intentionally 14 but let's do that.
15 different. They were a meandering conversation 15 So, things -- things weren't black and
16 over long periods of time. 16 white in the sense that you're trying to kind of
17 And so, as those conversations evolved and 17 put them in. It was more in the context of a
18 different people tried to formulate what it was 18 specific proposal.
19 people were talking about, and said, "Let's 19 Q Okay. As we discussed earlier, you
20 continue this. Let's sit down. Let's write a 20 prepared certain materials for presentations to
21 proposal." At different points, the proposals 21 the Board of Governors on the issue of
22 looked differently, and then there were reactions 22 concussions, right?
23 to proposals that were written down that 23 A Correct.
24 addressed different things. So... 24 Q And, of course, the Board of Governors are
25 Q I'm simply trying to get the lay of the 25 those who are appointed by the club as generally
Page 86 Page 88
1 the most senior people and owners that represent 1
2 the clubs, correct? The Board of Governors each 2
3 represents their club, correct? 3
4 A The Board of Governors is generally the 4
5 owner or the voting member on behalf of the club. 5
6 Q And the chairman of the Board of Governors 6
7 is actually an official of the National Hockey 7
8 League, correct? 8
9 A I, I don't know the corporate structure 9
10 of -- 10
11 Q So you're not aware that the chairman of 11
12 the Board of Governors has the ability to call 12
13 meetings? 13
14 MR. KEYTE: Objection. Foundation. 14
15 A I, I don't. 15
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Page 87 Page 89
1 1
2 2 Q Let me show you what I've marked as
3 3 Exhibit 6. And you will see this is a document
4 4 that bears, at the top, the words "Concussion
5 5 Report BOG Meeting, December 2009."
6 6 (Concussion Report BOG Meeting
7 7 Dec. 2009, Bates-stamped
8 8 NHL2081309 through 1315 was
9 9 marked as Exhibit 6 for
10 10 identification, as of this
11 11 date.)
12 12 Q It's a multipage document. And my
13 13 question is, did you prepare this document?
14 14 A I -- yes, I think I probably did.
15 15 Q Did anyone participate with you in
16 16 preparing this document?
17 17 A I may have gotten input from people.
18 18 Q Which people?
19 19 A I don't -- I may have gotten input from --
20 20 well, let me read the document.
21 21 (Reviews document.)
22 22 I -- I don't have a specific recollection.
23 23 My -- I may have talked to Ruben, I may have
24 24 talked to Winne. They are my medical advisors
25 25 and consultants who work with me on a frequent
Page 90 Page 92
1 basis on all of these matters, and have for all 1 Q And you're referring to several future
2 of the relevant time periods. So my general 2 projects that the Concussion Working Group may
3 practice would probably be to fact check with 3 consider, correct?
4 them and make sure I'm kind of conveying 4 A Yes.
5 information accurately. But I don't have a 5 Q Actually, it says that will be considered
6 specific recollection on this. 6 by the CWG, right?
7 Q You mentioned a moment ago that you have 7 A Yes.
8 presented to the Board of Governors on many 8 Q And under subparagraph B, it's a study on
9 occasions, right? 9 the long-term neurocognitive and psychological
10 A Yes. 10 effects of repeated concussions among retired NHL
11 Q And many of those occasions involved the 11 players, correct?
12 concussion issue, correct? 12 A Correct.
13 MR. KEYTE: Objection. Vague. 13 Q So, at least as of this time, the board is
14 A A concussion program. 14 being advised that such a study is in the works
15 Q Right. 15 or may be in the works, correct?
16 A And other matters, but yes. 16 A The board was advised that the concussion
17 Q Did you ever tell the Board of Governors 17 subcommittee was discussing this as a possible
18 that the Players' Association opposed a study of 18 future project, as the concussion subcommittee
19 retirees' neurocognitive health? 19 was.
20 MR. KEYTE: Objection. Overbroad. 20
21 Foundation. 21
22 A I, I don't recall. I don't recall. 22
23 Q Were you ever at a Board of Governors 23
24 meeting where you heard Mr. Daly say that the 24
25 Players' Association opposed a study of retirees' 25
Page 91 Page 93
1 neurocognitive health? 1
2 MR. KEYTE: Same objection. 2
3 A I don't recall. 3 Q Quickly, if you would turn to page 4.
4 Q Did you ever tell the Board of Governors 4 A Do you want me to refresh you on the state
5 that the PA opposed a study that would reflect 5 of the discussions? We've kind of been through
6 upon current players' neurocognitive health? 6 them chronologically.
7 A I don't remember. 7 Q No. Because you've already done it, and I
8 Q Did you ever tell the PA -- did you ever 8 think I remember them.
9 tell the Board of Governors that the PA opposed a 9 If you would turn to page 4.
10 study of retired -- strike that. 10 A Well, then your question didn't really
11 Did Mr. Daly, to your knowledge, ever tell 11 make any sense.
12 the Board of Governors that the PA wanted nothing 12 Q Won't be the first time that happens --
13 to do with the retiree study? 13 A Okay.
14 MR. KEYTE: Objection. Lacks foundation 14 Q -- at least from your perspective.
15 and mischaracterizes testimony. 15 A Okay.
16 A I don't think he would say that, because I 16 Yep.
17 don't think that's an accurate statement of our 17 Q Do you see under "playing environment" --
18 state of discussions. But I, I don't recall him 18 A Yes.
19 saying that, and I don't think that is a 19 Q -- it refers to a mandate that all clubs
20 statement he would make. 20 install a sufficiently flexible arena shielding?
21 Q If you would turn to page 6, here, 21 A Yes.
22 Ms. Grand. You see under the boldface section, 22 Q You were familiar with that change,
23 "Future Projects," there are a number of entries, 23 weren't you?
24 right? 24 A Yes.
25 A Yes. 25 Q And that is something that the NHL imposed
Page 94 Page 96
1 on its member clubs? 1 A The conversion to full acrylic that was
2 A This was something that emanated out of 2 done in 2012, yes, that was based on an analysis
3 the injury analysis panel, which was a panel that 3 of the data at that point, that showed that the
4 was an NHL, NHLPA, multidisciplinary panel. It 4 acrylic systems had a decreased level of injury
5 had, it was headed by Dave Dryden. It had, oh, 5 than the, than the other systems, yes.
6 gosh, probably 20 members on it including 6 Q And that was a change that was based, as
7 players. Paul Korea, Trevor Linden, it had 7 you say, on data that the NHL itself, with the
8 equipment manufacturers, it had equipment 8 PA, had analyzed, correct?
9 managers, it had trainers, it had doctors, it had 9 A Correct.
10 trainers, it had engineers, it had a lot of 10 Q And that data wasn't subject to peer
11 people. 11 review scrutiny, was it?
12 And so, emanating out of that group and 12 MR. KEYTE: Objection. Foundation.
13 analyses and work that that group had done, 13 Are you suggesting it says --
14 including hiring the engineering firm of Martin & 14 MR. GRYGIEL: I'm not suggesting anything.
15 Martin to do work on the relative flexibility of 15 I just want her to answer my question.
16 the box and board systems, this, this change was 16 MR. KEYTE: Well, you're -- objection.
17 made. 17 Foundation to your earlier question.
18 Q I appreciate the information, but my 18 A I, I don't believe that data had been
19 question was much narrower. 19 submitted to -- for peer review scrutiny.
20 This was a mandate that the League imposed 20 Q And you're not aware that that data was
21 on its member clubs and said, "Make these 21 subjected to an analysis for statistical
22 changes," correct? 22 significance, correct?
23 A Based on the collective work of the NHL 23 MR. KEYTE: Objection.
24 and NHLPA. 24 A I'm sorry. Can you repeat your question?
25 Q Right. So we're clear, you told me where 25 Q Sure. Are you familiar with the phrase
Page 95 Page 97
1 it came from. I simply want to talk about the 1 "statistical significance"?
2 effect. 2 A I am.
3 The NHL got this information and said to 3 Q Okay. Was that data subjected to testing
4 its clubs, "Make this change," correct? 4 for statistical significance before the change
5 MR. KEYTE: Objection. Overbroad. 5 was made?
6 A The League communicated to its clubs the 6 MR. KEYTE: Objection. Foundation.
7 requirement to make the change, yes. And the 7 A I, I'm not sure.
8 change came from the agreement of the NHL and the 8 Q Okay. Are you aware of any regression
9 NHLPA. I'm not sure if that's a distinction 9 analyses that were run on the injury rates
10 you're trying to get at, so I just want to be 10 against acrylic glass versus seamless glass in
11 clear. 11 making the determination that the clubs should
12 Q Well, the PA couldn't instruct the clubs 12 change their configuration?
13 to change the glass in their rinks, correct? 13 A I'm, I'm not familiar with -- I don't
14 A Yeah, I just, I wasn't sure if that was 14 recall the specific analyses that were done on
15 something you were trying to -- 15 it.
16 Q In fact, later, when the change was made 16 Q In general, data got obtained, it showed a
17 to go to fully acrylic, that was another 17 higher rate of frequency of injuries against the
18 situation where the NHL told its member clubs, 18 seamless glass, and the League made the change,
19 "You need to make this change"? 19 right?
20 A Yes. Again, based on the work that we had 20 MR. KEYTE: Objection. Foundation.
21 done together with the union. 21 A No, I, I don't think it was that
22 Q And that was, for example, work that 22 simplistic or flip of a decision.
23 demonstrated the frequency of injuries against 23 Q I didn't mean to be flip.
24 seamless glass as opposed to acrylic glass, 24 A Okay. It was a carefully monitored issue,
25 correct? 25 actually, over since 2000. And it was something
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8 as Exhibit 16 for 8
9 identification, as of this 9
10 date.) 10
16 encephalopathy." 16
18 you? 18
19 A Yes. 19
9 ahead of us. 9
10 A That's me. 10
11 Q And I did not mean intellectually, but 11
12 James knows what I meant. 12
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2 Q Mr. Campbell writes -- 2 Q And you had found Mr. Townend's feedback
4 Q Yeah. It was back May 20, 2013. 4 presentations that you were looking at then,
7 Q Right. 7 Q To PHATS.
8 A -- what he wanted us to present on at the 8 A Well, the PHATS presentation on, on, on
11 A And Coley was a little annoyed about 11 Q In fact, you said, This is good feedback
12 Gerry's comments about the officials? 12 and will be useful enabling us to prepare for our
13 Q And you're aware, of course, that 13 presentation, close quote, right?
14 Mr. Campbell spoke with Gerry, correct? 14 A Yeah, on the science, on the validity --
16 Q Coley asked for Gerry's phone number, 16 players asked for from the clubs, uh-huh.
18 A I remember they spoke. 18 the bottom of the second page in, about the
19 Q And then you got an e-mail later from 19 information Mr. Townend gave you generally,
20 Gerry saying, "Got an earful," right? 20 correct, and you're saying that note is useful.
23 Q Do you remember any follow-up with 23 A I, I was specifically talking about what
24 Mr. Townend, telling you exactly what 24 Gerry asked us to present on to the concussion --
25 Mr. Campbell said to him about this criticism of 25 to the PHATS group on our concussion subcommittee
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Page 394
1 CERTIFICATE
2
3 I, AMANDA McCREDO, a Shorthand Reporter
4 and Notary Public of the State of New York, do
5 hereby certify:
6 That the witness whose examination is
7 hereinbefore set forth, was duly sworn, and
8 that such examination is a true record of the
9 testimony given by such witness.
10 I further certify that I am not related to any
11 of the parties to this action by blood or
12 marriage; and that I am in no way interested in
13 the outcome of this matter.
14 Dated: 8/4/16
15
16 _______________
17 AMANDA McCREDO
18
19
20
21
22
23
24
25
Page 395
1 ERRATA SHEET FOR THE TRANSCRIPT OF:
2 Case Name: In re: National Hockey League
Players' Concussion Injury
3 Litigation
4 Dep. Date: August 3, 2016
5 Deponent: Julie Grand
6
7 CORRECTIONS:
8 Pg. Ln. Now Reads Should Read Reason
9 ___ ___ ______________ ________________ ______
10 ___ ___ ______________ ________________ ______
11 ___ ___ ______________ ________________ ______
12 ___ ___ ______________ ________________ ______
13 ___ ___ ______________ ________________ ______
14 ___ ___ ______________ ________________ ______
15 ___ ___ ______________ ________________ ______
16 ___ ___ ______________ ________________ ______
17 ___ ___ ______________ ________________ ______
18 ___ ___ ______________ ________________ ______
19
______________________
20 Signature of Deponent
21 SUBSCRIBED AND SWORN BEFORE ME
22 THIS___DAY OF___________, 20__
23
24 ______________________________
25 (Notary Public) MY COMMISSION EXPIRES:_________
Page 396
1 ACKNOWLEDGMENT OF DEPONENT
2 I, , do hereby
3 certify that I have read the foregoing
4 pages, and that the same is a correct
5 transcription of the answers given by me
6 to the questions therein propounded,
7 except for the corrections or changes in
8 form or substance, if any, noted in the
9 attached Errata Sheet.
10
11
12 ______________________________
JULIE GRAND
13
14 Subscribed and sworn to
15 before me on this_____ day
16 of ____________, ________.
17 _______________________________
18 Notary Public
19
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59:10 65:8 90:24 91:11 Daniel 76:13 73:14,20,25 dated 3:8,15 343:3
75:8 84:19 104:12,19 Danov 318:23 74:11,17 3:17 4:3,6,9 Dave 5:12
84:24 91:6 132:6,16,18 319:1 78:17,25 4:11,14,16 24:20 26:9
131:17 135:22 Darren 89:11 4:18,21,23 34:2,3,6
134:17 136:9,13 250:16,20 101:15 5:2,4,7,17 94:5 240:17
135:11 139:15 data 19:9,9 104:15 5:19,22 6:1 358:10,16
146:11 142:17 38:18 50:19 109:22 6:4,6,9,11 David 235:5
154:16,22 170:24 56:9 72:9 129:15 6:14,16,18 326:21
159:1 163:1 179:14 72:21 96:3 132:10,14 6:20,22 7:1 382:22
170:4 213:2 182:11,25 96:7,10,18 151:19,23 7:4,6,11,14 day 149:13
215:22 189:6,14 96:20 97:3 153:25 7:15,18,20 149:13
216:14 200:22 97:16 98:5 155:16 43:4 60:7 192:7
230:12,14 203:5 98:8 99:2,7 166:20 60:13 66:18 258:18
230:16 204:14 99:12 179:10 67:4 78:13 267:20
262:23,24 209:10,20 147:16,19 182:16,22 104:19 268:22
274:19 210:18,22 172:1 186:12,16 132:6,18 299:19
352:4 211:4 212:4 174:10 187:24 166:16 395:22
currents 212:7,14 176:14 198:8 179:6 396:15
64:21 213:9,11,18 177:10 199:19 182:11 days 16:5,8
cut 140:19 222:23 186:17 201:1 186:8 267:1 276:6
cutting 225:9 241:2 200:9 203:10 200:22 276:8
282:25 247:21,25 228:21 209:14,17 203:5 299:19
302:8 248:6 230:12 213:15 208:16 day-in 47:1
CWG 3:10 249:17,23 231:13 221:1 209:10 day-out 47:1
54:2,9 92:6 255:20 232:5,15 222:18 213:9,11 day-to-day
102:4 181:8 269:7 283:4 237:4,8,14 228:19 220:22 26:22 46:19
184:12 283:11 238:9,23 233:13 221:5 DD 358:12
cynical 288:19 242:20 239:22 222:14 dead 107:9
325:22 302:24 246:13,14 240:22 228:8,14 deal 46:22,22
326:6 303:20 249:15 247:19 240:25 46:25 55:24
C-A-S-S-O-N 316:20,25 251:6,6,7 248:3 255:10,18 242:11
364:2 317:14 252:12,13 255:14 283:5,12 248:22
C-I-F-U 235:5 320:4,10 252:20,22 283:9,15 288:10,19 350:18
321:2,6 257:12,20 288:15 301:18,25 dealing 18:9
D 323:14 257:21,22 301:22 308:12,18 44:22
D 2:9 3:1 326:10,17 257:25 302:18 318:10,15 125:10
8:23 140:21 326:19,20 258:3 308:8,17 321:6,25 307:18
191:19 326:22 276:10 318:14 322:5 352:21
daily 147:22 327:2 280:1,18 321:10 323:21 deals 56:14
192:10 328:24 282:6 322:10 324:4 153:4
Dalia 288:19 329:8,10 344:15 323:25 326:11 268:25
Daly 3:8,15 335:8,17 363:22,22 326:15 328:25 322:12
4:1,3,11,16 337:11 363:24 328:11 329:7 332:4 329:11
4:18,21,23 343:16 374:2 329:4 332:8 332:12 381:2
5:15,19 6:9 354:23 376:15 335:12,17 335:8 339:6 dealt 30:18
6:15,17,22 355:14 382:13 339:10 343:10 36:6,7 52:2
7:15,20 356:6,7 database 343:14 349:15,21 57:17 217:1
14:10,12 374:22 77:13,19 349:19 360:21 238:2
17:25 43:4 375:8,21 217:21 354:21 361:5 373:6 274:21
43:12,15 380:13 237:16 358:8 374:22 354:2
52:16,18 384:5 246:18 360:25 380:20 Dear 375:16
66:18 67:5 Daly's 101:20 330:4 366:12 381:1 384:6 death 69:14
74:24 76:21 303:1 date 1:19 373:9 375:1 394:14 73:15 74:11
77:21 78:6 327:25 43:8,10,23 380:24 dates 74:18 184:14
79:10 80:22 dangerous 54:7 59:24 384:10 123:24 193:18
81:8,12,18 158:1 60:2 66:22 395:4 daughters deaths
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