2015-08-27 - (Gapski, Mike) Final REDACTED - Condensed

Confidential Pursuant to Protective Order - Deposition of Mike Gapski - 8/27/2015
In Re: National Hockey League Players' Concussion Injury Litigation
Page 1
1 IN THE UNITED STATES DISTRICT COURT
2 NORTHERN DISTRICT OF ILLINOIS
3 EASTERN DIVISION
4
5 IN RE: NATIONAL HOCKEY
6 LEAGUE PLAYERS'
7 CONCUSSION INJURY MDL No. 14-2551
8 LITIGATION (SRN/JSM)
9
10 This Document Relates
11 to: ALL ACTIONS
12 The videotaped deposition of MIKE GAPSKI,
13 called for examination pursuant to the Rules of
14 Civil Procedure for the United States District
15 Courts pertaining to the taking of depositions,
16 taken before Vicki L. D'Antonio, a certified
17 shorthand reporter of the State of Illinois, at
18 161 North Clark Street, Chicago, Illinois, on
19 the 27th day of August, 2015, at the hour of
20 9:08 a.m.
21
22
23
24 Reported by: Vicki L. D'Antonio, CSR, RPR
25 License No.: 084-004344
Benchmark Reporting Agency

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1 APPEARANCES: 1 INDEX
2 WITNESS PAGE
2 3 MIKE GAPSKI
3 CORBOY & DEMETRIO, by 4 Examination by Mr. Gibbs............... 9
5
4 MR. WILLIAM T. GIBBS 6 EXHIBITS
5 33 North Dearborn Street 7
NUMBER PAGE
6 21st Floor 8
7 Chicago, Illinois 60602 Gapski Deposition
9
8 (312) 346-3191 Exhibit No. 1.......................... 8
9 wtg@corboydemetrio.com 10 Exhibit No. 2.......................... 9
Exhibit No. 3.......................... 80
10 11 Exhibit No. 4.......................... 99
11 -AND- Exhibit No. 5.......................... 133
12 12 Exhibit No. 6.......................... 142
Exhibit No. 7.......................... 146
13 BASSFORD REMELE, by 13 Exhibit No. 8.......................... 146
14 MR. JEFFREY D. KLOBUCAR Exhibit No. 9.......................... 148
14 Exhibit No. 10......................... 157
15 33 South Sixth Street Exhibit No. 11......................... 163
16 Suite 3800 15 Exhibit No. 12......................... 181
Exhibit No. 13......................... 186
17 Minneapolis, Minnesota 16 Exhibit No. 14......................... 188
18 (612) 333-3000 Exhibit No. 15......................... 194
17 Exhibit No. 16......................... 196
19 jklobucar@bassford.com Exhibit No. 17......................... 203
20 Representing the Plaintiffs; 18
19
21 NOTE: Exhibit No. 17 retained by Mr. Gibbs.
22 20
21
23 22
24 23
25 24
25
Page 3 Page 5
1 APPEARANCES: (Continued) 1 THE VIDEOGRAPHER: This is a videotaped
2 2 deposition of Mike Gapski in the matter of the
3 BRYAN CAVE, by 3 National Hockey League Players' Concussion
4 MR. CHRISTOPHER J. SCHMIDT 4 Injury Litigation, Case No. 14-2551 filed in the
5 MR. TIMOTHY J. HASKEN 5 United States District Court, District of
6 211 North Broadway 6 Minnesota.
7 Suite 3600 7 This deposition is being held at
8 St. Louis, Missouri 63102 8 161 North Clark Street, Chicago, Illinois on
9 (314) 259-2000 9 August 27th, 2015.
10 cjschmidt@bryancave.com 10 The court reporter is Vicki D'Antonio,
11 tim.hasken@bryancave.com
11 and I am Kevin Ingstrup, the videographer. We
12 Representing the Chicago Blackhawks;
12 are both from the firm of Benchmark Reporting
13
13 Agency in Minneapolis, Minnesota.
14 PROSKAUER ROSE, LLP, by
14 We are going on the record at 9:08 a.m.
15 MR. ADAM M. LUPION
15 Will counsel please state their
16 Eleven Times Square
16 appearances for the record.
17 New York, New York 10036
17 MR. SCHMIDT: Chris Schmidt with Bryan Cave
18 (212) 969-3000
18 on behalf of the Chicago Blackhawks.
19 alupion@proskauer.com
20 Representing the National Hockey 19 MR. HASKEN: Timothy Hasken, Bryan Cave, on
21 League. 20 behalf of the Chicago Blackhawks.

22 21 MR. LUPION: Adam Lupion, Proskauer Rose, on
23 ALSO PRESENT: 22 behalf of the National Hockey League.
24 Ms. Fallon Faia, Corboy & Demetrio 23 MR. KLOBUCAR: Jeff Klobucar with the law
Mr. Andrew Stevens, Corboy & Demetrio 24 firm of Bassford Remele on behalf of the
25 Mr. Kevin Instrup, Videographer 25 plaintiffs.

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1 MR. SCHMIDT: And Bill Gibbs of Corboy & 1 we do have a couple of authorizations.
2 Demetrio, also on behalf of the plaintiffs. 2 MR. SCHMIDT: Yeah. Should we get those
3 I'll just note, also present from my 3 admitted right now? That way, it will
4 office are Andrew Stevens and Fallon F-A-I-A. 4 allow -- I believe it's for Dan Carcillo and
5 THE VIDEOGRAPHER: Thank you. 5 also for Steve Montador?
6 Will the reporter please swear in the 6 MR. GIBBS: Correct. So I'm not sure if we
7 witness. 7 need to make these exhibits.
8 (Whereupon, the witness was duly 8 MR. SCHMIDT: I think we should.
9 sworn.) 9 MR. GIBBS: But maybe we should, right?
10 MR. GIBBS: Mr. Gapski, we're going to take 10 MR. SCHMIDT: Yeah.
11 care a few just kind of preliminary matters 11 MR. GIBBS: Let's do -- Exhibit 1 will be an
12 before we get started questioning you. 12 authorization executed by Paul Montador as
13 First, I think Chris wants to put 13 executor of the estate of Steve Montador as of
14 something on the record regarding the 14 August 22, 2015.
15 designation of the deposition. 15 (Whereupon, Gapski Deposition
16 MR. SCHMIDT: Yes. We're going to, 16 Exhibit No. 1 was marked for
17 consistent with the Court's protective order, 17 identification.)
18 designate the entire transcript as confidential, 18 MR. GIBBS: And I've got copies for you guys.
19 subject to the parties' ability to meet and 19 MR. SCHMIDT: Thank you.
20 confirm, de-designate portions later. 20 MR. LUPION: Thank you.
21 MR. LUPION: And also to the extent that one 21 MR. GIBBS: And Exhibit 2 will be an
22 party objects to a question that is deemed to 22 authorization executed by Daniel Carcillo as of
23 apply to all, both the club and the National 23 August 25th, 2015.
24 Hockey League. 24
25 MR. GIBBS: So that's agreed, and we were 25
Page 7 Page 9
1 looking at Pretrial Order No. 6 last night. 1 (Whereupon, Gapski Deposition
2 MR. SCHMIDT: Sure. 2 Exhibit No. 2 was marked for
3 MR. GIBBS: Paragraph 10 says that the 3 identification.)
4 examining attorney may elect to waive the 4 MR. SCHMIDT: Thank you, sir.
5 requirement that objections be voiced regarding 5 MR. LUPION: Thanks.
6 matters that may be remedied if presented at the 6 MR. GIBBS: And with that, I think that
7 time and allow those objections to be preserved, 7 pretty much takes care of our kind of initial
8 in which event, such objections are unnecessary 8 stuff.
9 and shall not be made. 9 MR. SCHMIDT: I agree.
10 So I certainly will waive, you know, 10 MR. GIBBS: All right.
11 any requirement that you object to form, you 11 MR. SCHMIDT: Thank you.
12 know, through the entire deposition, really, and 12 MIKE GAPSKI,
13 then, you know, subject to you -- you raising it 13 having been first duly sworn, was examined and
14 at a later time. 14 testified as follows:
15 MR. SCHMIDT: I'll reserve my right to 15 EXAMINATION
16 object, but I -- I appreciate that. 16 BY MR. GIBBS:
17 MR. GIBBS: Yeah. And with that being made, 17 Q. Mr. Gapski, have you ever given a
18 I think, you know, it pretty much is privilege 18 deposition like this before?
19 would be the only objection that would be... 19 A. No, I've not.
20 MR. SCHMIDT: Let's do the deposition and see 20 Q. Okay. I'm going to go through a few
21 how -- how it proceeds. I have no intention 21 kind of general ground rules of what we're up to
22 to -- to say -- state a lot of objections. 22 today. I'm sure you've gone through it with
23 MR. GIBBS: All right. Well, we'll -- we'll 23 your counsel, but I just want to refresh your
24 proceed under that. 24 recollection on -- on a few things.
25 I also mentioned to you last night that 25 First, if I ask a question that you

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1 don't understand or doesn't make sense, I would 1 Q. And how long has Mr. Thomas been in
2 ask that you ask me to rephrase it before 2 that role?
3 answering a question. If you do answer a 3 A. I believe ten years.
4 question, I'm going to presume that you've 4 Q. Prior to Jeff Thomas, did you have
5 understood the question. Is that fair? 5 someone else in that role?
6 A. Yes. 6 A. Yes.
7 Q. Just like you're doing right now, 7 Q. And who was that?
8 please make sure that your answers are out loud 8 A. Michael Keating.
9 for the record so that nods of the head, 9 Q. And how long was he in that position?
10 uh-huhs, or uh-uhs won't be accurately 10 A. I'm not sure. Probably four to six
11 transcribed, so we want to make sure there's an 11 years.
12 accurate record with affirmative answers to 12 Q. And before Mr. Keating?
13 every question. Okay? 13 A. Craig Brehmer.
14 A. Yes. 14 Q. And how long was he in the role?
15 Q. Because Vicki is taking everything down 15 A. I think two years.
16 that we say, in ordinary conversation, we may 16 Q. Before Mr. Brehmer?
17 kind of speak over each other or anticipate 17 A. No one.
18 where one another is going. If we could just 18 Q. You were on your own as the only
19 make sure that -- that we kind of give a pause 19 trainer for the Blackhawks?
20 between one another's statements, that will make 20 A. Yes.
21 her job a lot easier today. Okay? 21 Q. In addition to yourself, who else from
22 A. Yes. 22 the Blackhawks today is responsible for the care
23 Q. If there is an objection, and I don't 23 and treatment of the players?
24 think there are going to be, you know, based on 24 A. Our team physician, Dr. Michael Terry.
25 kind of the arrangement that we have, but if 25 We have other physicians on staff. Dr. Angelo
Page 11 Page 13
1 there is an objection, unless your counsel has 1 Costas, he's an internist. Dr. Mike Terry is an
2 instructed you not to answer, you are to answer 2 orthopedic surgeon. He's our head team
3 the question, even in the presence of an 3 physician. Angelo Costas would be considered
4 objection. Okay? 4 our head internist. We have other consults that
5 A. Yes. 5 we use that aren't -- wouldn't be considered,
6 Q. What is your current job title? 6 like, head physicians. We have a team -- a team
7 A. Head trainer for the Chicago 7 dentist, group of dentists, Dr. Russ Baer,
8 Blackhawks. 8 Dr. Marty Marcus, and Dr. Mike Marcus.
9 Q. And how long have you been in that 9 Q. Do -- do you utilize a team
10 position? 10 neuropsychiatrist?
11 A. 28 years. 11 A. Yes, we do.
12 Q. What are your duties and 12 Q. And who's that?
13 responsibilities today as the head athletic 13 A. Dr. Beth Pieroth.
14 trainer of the Chicago Blackhawks? 14 Q. How long have the Blackhawks been using
15 A. I'm responsible for all medical care of 15 Dr. Pieroth?
16 all of our players. 16 A. I'm not exact sure on the exact amount
17 Q. And has that been the same job 17 of time, but probably around ten years.
18 description for the entire 28 years that you've 18 Q. And are there any other specialists
19 been in that role? 19 that the Blackhawks utilize in relation to the
20 A. Yes. 20 care and treatment of players' brain injuries?
21 Q. Do you have an assistant athletic 21 A. Not that I recall. I mean,
22 trainer -- athletic trainer? 22 occasionally, we may use Dr. Hain out of the
23 A. Yes. 23 dizzy -- center for dizziness on occasion, and
24 Q. And who's that? 24 that would be all that I can recollect.
25 A. Jeff Thomas. 25 Q. And going back in time, 28 years means

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1 you began in that role in what year? 1 assisting in that way?
2 A. 1987. 2 A. I think approximately a year or two.
3 Q. Okay. 1987, who was involved in the 3 He was a neuropsychologist.
4 care and treatment of players, along with the 4 Q. And was that during the -- the kind of
5 trainer? 5 early 2000s?
6 A. Dr. Louis Kolb was our head physician. 6 A. '97, I think, right around then. When
7 He was also an orthopedic surgeon. Dr. Howard 7 the league instituted the NHL concussion
8 Baim was an ENT who acted as our internist. 8 protocol.
9 Dr. Duresa, who was our team dentist. 9 Q. Got you.
10 Q. At that time back in '87, did you have 10 We just used the term "concussion,"
11 anyone -- any specialists that the Blackhawks 11 which will be utilized, you know, a lot today.
12 were utilizing in the care and treatment of 12 What is your definition of a
13 players' brain injuries? 13 concussion?
14 A. Consult would be Dr. Hilliard Slavick. 14 MR. SCHMIDT: Just object to -- to form, but
15 Q. And how -- when did Dr. Slavick's 15 subject to that, you may answer.
16 relationship with the team come to an end? 16 MR. GIBBS: Yeah. Again, I waive, you know,
17 A. When Louis Kolb left. 17 your re- -- your need to do that, so --
18 Q. Which was around what year? 18 MR. SCHMIDT: And I reserve my right.
19 A. I think it was 1997. 19 THE WITNESS: Can you clarify that? A
20 Q. From the time you started until 20 concussion is -- is -- is -- in terms is -- is
21 Dr. Slavick left, were there any other 21 pretty -- depending upon who you're reading and
22 physicians that the Blackhawks utilized in the 22 what definition you're talking about, there's
23 care and treatment of players' brain injuries? 23 a -- there's numerous definitions out there
24 A. Not that I recall. 24 regarding concussion. The NHL states or the --
25 Q. Now, when Slavick left in '87, 25 the Zurich conference states one thing, so
Page 15 Page 17
1 did -- who took over -- 1 theoretically or what they say is any altered
2 A. '97. 2 state of the brain.
3 Q. '97, I'm sorry, who took over the care 3 BY MR. GIBBS:
4 and treatment of players' brain injuries, if 4 Q. And I'm just wondering what your
5 anyone? 5 definition is.
6 A. Dr. George Cybulski was a neurosurgeon. 6 MR. SCHMIDT: Object to form.
7 Q. And how long did -- did he assist the 7 THE WITNESS: A -- what I would term is a
8 team in that way? 8 concussion is anytime somebody elicits certain
9 A. I don't recall. Two, three years, 9 signs that would regard -- that would -- would
10 maybe. 10 indicate that there's something going on in
11 Q. So that brings us roughly to 2000? 11 a person's head.
12 A. Approximately. There may be -- I 12 BY MR. GIBBS:
13 don't exact -- I can't recall when the 13 Q. Okay. And what are those signs?
14 neuropsych program or the -- the NHL concussion 14 A. Dizziness, nausea, inst- --
15 protocol started, which means Beth and one other 15 instability, confusion, loss of memory,
16 physician would have kind of stepped in also, 16 unconsciousness.
17 along with George Cybulski. 17 Q. Anything else?
18 Q. Okay. So have we identified all of the 18 A. Inability to recall certain things,
19 physicians that have taken care of Blackhawks 19 confusion, not feeling themselves, sensitive to
20 players' brain injuries during your tenure with 20 light, sensitive to noise.
21 the Blackhawks? 21 Q. Any other signs that indicate to you
22 A. No. 22 that a player may have suffered a concussion?
23 Q. Who else? 23 MR. SCHMIDT: Object to form, asked and
24 A. Dr. Bob Hielbronner. 24 answered.
25 Q. And how long was Dr. Hielbronner 25 THE WITNESS: Can you clarify that?

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1 BY MR. GIBBS: 1 Q. Got you.
2 Q. You just gave me ten signs. 2 And at St. Rita, did you participate in
3 Are there any others? 3 athletics?
4 A. Those are -- those are symptoms. 4 A. I tried out for the football team. I
5 Q. Are there -- 5 had knee surgery, so I gave that up and I played
6 A. Signs are different than symptoms. 6 in the band.
7 Q. Okay. Are there any other signs and 7 Q. Did you do any athletic training?
8 symptoms of concussion other than the ten that 8 A. No.
9 you've just mentioned? 9 Q. At St. Rita, did you have any education
10 MR. LUPION: Object to form. 10 or training on concussions or traumatic brain
11 MR. GIBBS: Well, again, we don't have to 11 injuries?
12 keep doing that. I've -- I've, pursuant to the 12 A. No.
13 pretrial order, indicated that I waive that, and 13 Q. After graduating from St. Rita, you
14 pursuant to the pretrial order, if I've waived 14 went to city college?
15 it, then you shouldn't make form objections. 15 A. Yes.
16 MR. LUPION: Can I see a copy of the pretrial 16 Q. For two years?
17 order? 17 A. Yes.
18 You may proceed. 18 Q. And what did you study there?
19 THE WITNESS: Okay. Signs and symptoms 19 A. Chemistry.
20 are -- are two different things, so to -- you'd 20 Q. During your studies at city college,
21 have to put me in a situation where I would be 21 did you have any education or training regarding
22 able to -- to observe a sign versus a symptom. 22 concussions or traumatic brain injury?
23 BY MR. GIBBS: 23 A. No.
24 Q. Okay. Well, let's go through the signs 24 Q. After city college, then you went over
25 of concussion that you look for. 25 to UIC?
Page 19 Page 21
1 A. The signs of concussion I look for? 1 A. Yes.
2 Blow to the head, clutching/grabbing the head, 2 Q. And what was your major at UIC?
3 instability on the ice, extended amount of time 3 A. Started in chemistry and was changed to
4 to get up off the ice, significant blow to the 4 physical -- physical education with an emphasis
5 face. That's pretty much it. 5 on athletic training.
6 Q. And what are the symptoms -- 6 Q. Okay. Now, during your undergraduate
7 A. Symptoms are what -- 7 studies at the University of Illinois at
8 Q. -- of concussion that you look for? 8 Chicago, did you receive any training or
9 A. The symptoms are what I've explained to 9 education regarding concussions or traumatic
10 you at first, the -- 10 brain injury?
11 Q. The ten things? 11 A. Yes.
12 A. Yeah, the ten things. 12 Q. And in what form did that -- did that
13 Q. Other than the five signs and the ten 13 education and training take?
14 symptoms that you've identified, are there any 14 A. Athletic training coursework, advanced
15 other signs or symptoms of concussion? 15 first aid, and, you know, athletic training
16 A. There -- I'm sure there -- there 16 courses, practicums [sic].
17 probably are. At this point, I just can't 17 Q. Do you, as you sit there today,
18 remember them. 18 remember any of the -- the textbooks that you
19 Q. Okay. Now, you went to St. Rita? 19 utilized in learning about concussions or
20 A. I did. 20 traumatic brain injury back at UIC?
21 Q. What year did you graduate from Rita? 21 A. I can't remember who wrote the book,
22 A. 1976. 22 but it was Principles of Athletic Training.
23 Q. So what parish would you have grown up 23 Q. And is that a textbook that continues
24 in? 24 to be produced, you know, even -- even up to
25 A. St. Rita. 25 today with subsequent editions?

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1 A. I'm not sure. At the time, that was 1 athletic training to UIC hockey players?
2 the state of the -- the state of the art 2 A. I believe from 1980 to 1987. It might
3 athletic training textbook. We've also used the 3 have been '81. I'm not sure.
4 American Red Cross first aid and advanced first 4 Q. And during those years, were the signs
5 aid books, and I used one other emergency 5 and symptoms of concussion that you were looking
6 management book. I don't recall the exact name 6 for in those players the same signs and symptoms
7 of it, though. 7 that we've identified here today?
8 Q. In addition to your coursework at UIC, 8 A. Yes.
9 you began doing some athletic training? 9 Q. During your time at UIC, did you ever
10 A. Yes. 10 learn, whether through -- through coursework or
11 Q. And was that the first time that you'd 11 conversation, that a concussion that is not
12 ever kind of performed that role? 12 properly managed could lead to permanent
13 A. Yes. 13 effects?
14 Q. Okay. Tell me a little bit about that. 14 A. No, I didn't learn that, because, I
15 Were you working under someone at that 15 mean, in my care, my -- my priority is to take
16 time? 16 care of our athletes and their -- and -- and
17 A. I was working under -- under head 17 health is their first risk, and I don't believe
18 trainer, Tim Ashby. 18 that we've ever mismanaged any concussions, so I
19 Q. And he was the head trainer for the -- 19 don't think I ever had that conversation.
20 A. He was the head trainer and also the 20 Q. During that time at UIC, did you ever
21 instructor or the director of the athletic 21 learn that repetitive head trauma could lead to
22 training program at the time. 22 long-term cognitive or mental health issues?
23 Q. Okay. And what sports were you 23 A. I don't recall.
24 assisting him in athletic training? 24 Q. You became the Hawks' head athletic
25 A. I was assisting in all sports. 25 trainer in '87, then?
Page 23 Page 25
1 Prima- -- my -- my primary -- my primary -- 1 A. Correct.
2 primary role was in -- assisted the hockey team. 2 Q. Did you receive any training or
3 Q. And who was the head hockey coach at 3 education from the National Hockey League prior
4 UIC back then? 4 to signing on as the Hawks' trainer?
5 A. The first coach was John Kantarski. 5 A. No.
6 Q. And was he the -- the head coach then 6 Q. Once you signed on as the Hawks'
7 when you were in your undergraduate years? 7 trainer, did the National Hockey League provide
8 A. My first year. 8 you with any education or training?
9 Q. How about second year? 9 A. No.
10 A. It would be Val Belmonte. 10 Q. Do you know whether back in 1987 when
11 Q. Was your role with UIC to -- part of 11 you first became the Hawks' athletic trainer
12 your role to provide care and treatment to UIC 12 whether the National Hockey League had any
13 hockey players who had suffered brain injuries? 13 policies, procedures, or protocols in place
14 A. All injuries. 14 related to head injury?
15 Q. And that would include brain injuries? 15 A. I don't recall. As a certified trainer
16 A. Yes. 16 of the league, the league required -- would ask
17 Q. And a concussion is a brain injury. 17 that all trainers be certified by the National
18 You would agree with that? 18 Athletic Trainers' Association, and that would
19 A. Yes. 19 be -- in that certification, all aspects of
20 Q. Did you receive any kind of on-the-job 20 concussion and injuries were -- were -- we were
21 training from the head athletic trainer 21 educated on.
22 regarding how to assess players for signs of 22 Q. Okay. So that was something that we
23 concussion or other brain injury? 23 kind of didn't talk about, being certified by
24 A. I don't recall. 24 National Athletic Trainers' Association.
25 Q. How long did you continue to provide 25 When -- when did you get certified?

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1 A. 1982. 1 continuing education?
2 Q. And when certified in 1982, what, if 2 A. Continuing, it would be different
3 any, education or training did you receive 3 coursework. It would be -- there's a -- there's
4 regarding head injury? 4 a national convention which -- which provides
5 A. In order to -- in order to become 5 clinical symposiums on all aspects of athletic
6 certified as an athletic trainer, at that time, 6 training. I think it's a three- or four-day
7 you were -- you were required to -- you were 7 yearly conference.
8 required to have a bachelor's degree of physical 8 In addition to that, the Illinois
9 education with an emphasis on athletic training 9 Trainers Association or District 4 also has a
10 courses. In addition to that, you were required 10 district convention in which you -- we attend,
11 to undergo 1600 hours of clinical experience. 11 all which we -- we accrue the part -- part of
12 After that, you were eligible to take the NA -- 12 the 75 hours and they offer different symposiums
13 National Athletic Trainers' Association 13 and clinics on -- on various aspects of athletic
14 certification exam, and which I did. 14 training. I don't recall if I attended
15 Q. And so that exam, is there -- is that a 15 specifically a one on concussions.
16 written exam? 16 Q. So is it true that other than the
17 A. It's a two-part exam. It's a written 17 requirement that you be NATA certified, the
18 exam and along with a practical exam at the 18 National Hockey League as of 1987 didn't have
19 time. 19 any requirement that you undergo training or
20 Q. And were -- were there any written 20 education in the treatment of head injuries?
21 materials that you were provided to study up for 21 A. As a certified trainer, no. It's
22 the written portion of the exam? 22 expected to know these things.
23 A. There is no form of pre -- what do they 23 Q. Okay. And that's just what I want to
24 call it, prep -- preparatory work done. 24 know.
25 Q. Okay. Did you, in fact, pass that 25 The -- the league didn't do anything
Page 27 Page 29
1 examination in 1982? 1 beyond that?
2 A. Yes. 2 A. Not to my knowledge.
3 Q. Now, from '82 until '87, did you 3 Q. Let's take a ten-year window, '87 to
4 receive any continuing education in order to 4 '97. During that first ten years that you were
5 keep up your NATA certification? 5 with the Blackhawks, did the National Hockey
6 A. Yes. It's mandatory through the NATA 6 League provide you with any training or
7 that we -- we con- -- we receive continuing 7 education on the treatment of head injuries?
8 education course -- do -- do continuing -- 8 A. They may have.
9 continuing education courses. 9 Q. Okay.
10 Q. And is there an hourly requirement per 10 A. In that at our -- in addition to the
11 year or how does that work? 11 national athletic training meetings that -- that
12 A. At the time, I think it was 75 hours 12 are held once a year that -- that I attend as
13 for three years. 13 part of my 75 hours, the National Hockey League
14 Q. So -- so you would have to report your 14 Trainers Association, which we now call PHATS,
15 continuing education every three years? 15 also had a yearly conference in which we would
16 A. Yes. 16 attend to -- to accrue some more hours for our
17 Q. And did you, in fact, report that in 17 CEUs, which would have a number of symposiums
18 '85, if you recall? 18 and educational meetings regarding various
19 A. Yes. 19 topics on athletic training.
20 Q. Do you recall whether any of the 20 Q. So was the National Hockey League
21 continuing education that you received from '82 21 Trainers Association in place as of 1987 when
22 to '85 encompassed the treatment of brain 22 you be- -- when you began?
23 injuries or any type of head injury? 23 A. Yes.
24 A. I don't recall. 24 Q. And did that association have annual
25 Q. And what would that consist of, the 25 meetings beginning, as far as you know, or as

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1 far back as 1987? 1 question.
2 A. Yes. 2 MR. SCHMIDT: I'm -- I'm going to -- I'm
3 Q. Do you recall any specific 3 going to actually interrupt at this point
4 presentations that were focused on head injuries 4 because you've now asked four times and he's
5 at the National Hockey League Trainers 5 giving an incredibly clear answer on -- on the
6 Association annual meeting in 1987? 6 record, and Counselor, I'd ask you to move on
7 A. I don't recall. 7 and I will assert my right to object if you keep
8 Q. And do you recall any specific 8 badgering the witness with the same question
9 presentations at the National Hockey League 9 over and over.
10 Trainers Association, or PHATS, annual meetings 10 MR. GIBBS: I am not badgering at all.
11 in the first decade that you were athletic 11 BY MR. GIBBS:
12 trainer for the Chicago Blackhawks? 12 Q. I -- I just want to know if you got
13 A. I don't recall. 13 anything from the NHL in your first ten years
14 Q. Okay. During that first decade, did 14 related to how you should care for players' head
15 you yourself make any presentations at any -- in 15 injuries. That's all I want to know.
16 any forum regarding the treatment of head 16 MR. SCHMIDT: Object to form, asked and
17 injuries? 17 answered.
18 A. Not during that time, no. 18 THE WITNESS: No.
19 Q. Do you know whether the National Hockey 19 BY MR. GIBBS:
20 League had any policies, procedures, or 20 Q. During those first ten years as
21 protocols in place during your first ten years 21 athletic trainer for the Chicago Blackhawks, did
22 on the job related to athletic trainers' 22 you observe signs or symptoms of concussion
23 treatment of head injuries? 23 following any type of head trauma to a
24 MR. SCHMIDT: Object to form, asked and 24 Blackhawks player?
25 answered. 25 A. I don't recall specific incidents --
Page 31 Page 33
1 THE WITNESS: No. They -- as a certified 1 incidents, but I'm sure I did.
2 athletic trainer, we would -- we were required 2 Q. Okay. During that time, again, kind of
3 to -- to know the care and management -- 3 those first ten years, if you noticed a player
4 recognition, care, and management of -- of these 4 exhibiting a sign or symptom of concussive brain
5 injuries. 5 trauma, what would you do?
6 BY MR. GIBBS: 6 A. I would remove them from playing. I
7 Q. Okay. And all I'm saying is -- is the 7 would -- we would eval- -- do an initial
8 league didn't have any specific policies, 8 evaluation and then we would turn the -- the
9 procedures, or protocols in addition to that 9 parti- -- player over to a physician for a
10 which you -- you would have received from or as 10 diagnosis. Athletic trainers don't diagnose, we
11 part of your certification; is that true? 11 evaluate, so all concussions -- all our
12 MR. SCHMIDT: Asked and answered. 12 concussions were diagnosed by our team
13 THE WITNESS: As a certified trainer, we are 13 physician.
14 responsible to know these things, and they 14 Q. During -- during those first ten years,
15 expected us, and at some point in time, I -- I 15 was it your sole responsibility to decide when a
16 don't remember what it's called, it was required 16 player should be removed from play in order to
17 by the NHL, NHLPA for all athletic trainers to 17 be evaluated for potential concussion?
18 be certified, which would include -- in our 18 A. Not sole job. I'm -- I'm -- it would
19 certification, which would include education 19 also be part of the physician's job also.
20 and -- on recognition and management and 20 Q. Okay. And tell me how that works, kind
21 treatment of concussions. 21 of how that interplay is between the athletic
22 BY MR. GIBBS: 22 trainer and the team physician as it relates to
23 Q. Okay. But -- and I -- I do keep -- I 23 removing a player following an exhibited sign or
24 will acknowledge I keep asking the same 24 symptom of concussion.
25 question, but I'm not getting an answer to the 25 A. If the -- a physician was -- was --

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1 like, our physicians at the time were close by 1 Q. -- do you remember any specific
2 the bench. If they -- if they recognized signs 2 instances?
3 or symptoms, they would -- and I perhaps didn't 3 A. I don't remember, no.
4 see something, they can recommend or we would 4
5 just, you know, agree to take the person off. 5
6 Q. Okay. 6
7 A. Other than that, I would evaluate them. 7
8 If I -- if they exhibited any symptoms or signs, 8
9 then they would be removed for further 9
10 evaluation. 10
11 Q. And what would that evaluation look 11
12 like from your perspective? 12
13 A. It's like a four-point sign, symptom, 13
14 an eye test, looking for an astigmatism in the 14
15 eye, series of questions, both difficult and -- 15
16 and easy to answer on recognition to find out if 16
17 there was any what appeared to be an altered, 17
18 you know, state. 18
19 Q. And if after evaluation the -- the 19
20 symptoms demonstrated to you that the player may 20
21 be exhibiting symptoms of a concussion, you 21
22 would then turn them over to the physician for a 22
23 diagnosis? 23
24 A. Correct. 24
25 Q. During those years, were there players 25
Page 35 Page 37
1 that, after you recognized symptoms of 1
2 concussive brain trauma and you turned them over 2
3 to the physician, the physician did not diagnose 3 Q. And so am I correct that a player who
4 concussion? 4 has been diagnosed with concussion should not
5 A. Possibly. 5 continue to participate in hockey until he is
6 Q. Do you recall any specific instances? 6 symptom free?
7 A. No specific incidents. 7 A. Symptom free -- symptom free both upon
8 Q. Do you know whether, again, during 8 rest and exercise.
9 those first ten years any of the Blackhawks 9 Q. And is the same true for a player that
10 players continued to play in the same game after 10 exhibits signs or symptoms of concussion, he
11 exhibiting a sign or a symptom of concussion? 11 should not continue to participate until he is
12 A. I don't recall. I mean, it was the 12 symptom free?
13 team's physician's responsibility to -- to -- to 13 A. Correct.
14 clear a player, but I -- I -- I don't recall. 14 Q. And why is that?
15 Q. You don't recall any specific 15 A. If they're symptomatic, there's
16 instances -- 16 obviously something that's going on, and then we
17 A. No. 17 do not -- we -- we -- obviously, with our
18 Q. -- where you removed a player for 18 education, that's not the right thing to do to
19 evaluation, recognized a sign or symptom, but 19 put a player back into a par- -- you know, a
20 the player continued to play in the same game? 20 contact sport when they're under -- when they're
21 A. If he was evaluated by the physician 21 still undergoing some -- some symptoms.
22 and they cleared him, that may have happened and 22 Q. Would it increase the player's risk for
23 occurred. I -- I -- I don't recall. 23 further injury if the player continued to play
24 Q. And I'm just wondering -- 24 with demonstrated signs or symptoms of
25 A. Yeah. 25 concussion?

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1 MR. LUPION: Object to form. 1 A. Three.
2 THE WITNESS: Possibly. 2 Q. And for how long a period of time?
3 BY MR. GIBBS: 3 A. Six hours.
4 Q. And what further injury are they 4 Q. During those conversations with your
5 risking by doing so? 5 attorney, which I don't want to know anything
6 A. Every case is -- is different. It's -- 6 about, was anyone else present?
7 I mean, I can't answer that. It's -- it's 7 A. No.
8 dependent upon the symptoms, dependent upon, you 8 Q. Did you at any time leading up to
9 know, the player, their role. 9 today's deposition have any conversations with
10 Q. I asked you before whether during your 10 any lawyer representing the National Hockey
11 time at UIC you ever heard that repetitive head 11 League?
12 trauma could lead to permanent damage. 12 A. I did not.
13 During those first ten years with the 13 Q. Did you at any time leading up to your
14 Blackhawks, did you ever hear that repet tive 14 deposition today have any conversations with any
15 head trauma could lead to permanent damage? 15 member of the Blackhawks organization?
16 A. I may have through one of our 16 A. Regarding this?
17 symposiums. 17 Q. Yes.
18 Q. And what d d you hear about that? 18 A. No.
19 A. I don't know the specifics. 19 Q. Did you at any time leading up to your
20 Q. Do you know whether the National Hockey 20 deposition today have any conversations with
21 League during those ten years ever warned its 21 anyone from the National Hockey League?
22 players that repet tive head trauma could lead 22 A. No.
23 to permanent injury? 23 Q. Did you at any time leading up to your
24 A. I don't recall, but, I mean, it's a 24 deposition today have any conversations with any
25 joint venture between the NHL and the NHLPA, so 25 colleagues in the athletic training realm?
Page 39 Page 41
1 they may have discussed that with their players 1 A. No.
2 because that was -- you know, that's a -- 2 Q. How about physicians?
3 concussions are a big issue, so I don't know 3 A. No.
4 specifically if there was anything in play, but, 4 Q. Did you review any documents?
5 you know, separately, I know there was warnings. 5 A. Yes.
6 I don't recall which -- which date and time that 6 Q. Okay. Did you review any documents
7 would -- that would go out to the players 7 that -- in addition to those that I designated
8 through the Players' Association through league, 8 as potential exhibits for today's deposition, if
9 you know, warning these players to be honest 9 you know?
10 about their symptoms and signs, report that to 10 A. I don't know.
11 your -- report that to your medical staff so 11 Q. From 1997 to 2007, your second decade
12 that you can undergo the right -- the proper 12 on the job, do you know whether the National
13 care and treatment. 13 Hockey League ever warned its players of the
14 Q. But as you sit there today, you're not 14 risk of permanent injury as a result of
15 aware of any specific -- 15 repetitive head trauma?
16 A. Specific -- 16 A. I believe so, yes.
17 Q. -- warnings from the league to the 17 Q. And what form did that take?
18 players regarding the -- the risk of permanent 18 A. The -- there -- there used to be FAQ
19 damage as a result of repetitive head trauma, 19 papers and I'd at the time post FAQ papers that
20 true? 20 would come out to the players. I think the
21 A. I don't recall that. 21 Players' Association would e-mail, possibly mail
22 Q. Prior to your deposition today, what 22 those to the players, and they would require the
23 did you do to prepare? 23 athletic trainers to post those on the -- in
24 A. Just talked to my attorney. 24 the -- in the locker rooms. We would post ours
25 Q. On how many occasions? 25 on the bulletin board, typically, in the

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1 player's lounge. 1 were in the form of the FAQs and the materials
2 Q. And do you know when the league began 2 related to the neuropsych testing; is that true?
3 sending out those FAQs? 3 MR. LUPION: I'm going to object to the form.
4 A. I think I saw the first one, if I 4 It mischaracterizes the witness's testimony.
5 re- -- 2000, before that. But before that, 5 MR. SCHMIDT: I'll join. He's -- he's
6 there may have been verbal messages because the 6 explained several times those were joint
7 Players' Association and the NHL had to agree on 7 warnings by the NHLPA and the NHL. Counselor,
8 neuropsychological testing, so the players 8 you're -- you're arguing with the witness at
9 obviously knew that there was concussion issues 9 this point. I'd ask you to move on at this
10 out there that were going to -- and that we were 10 point.
11 going to take measures to evaluate and research 11 BY MR. GIBBS:
12 them. 12 Q. Can you answer the question?
13 Q. So from '97 to 2007, your knowledge of 13 A. Specifically, I don't recall.
14 the extent of the -- the NHL's warnings 14 Q. Are you aware of the National Hockey
15 consisted of FAQs which would have been sent to 15 League providing warnings to its players that
16 you and then posted by you and the materials 16 repetitive head trauma could cause permanent
17 that would have been provided to players 17 injury from 2007 to the present?
18 vis-à-vis neuropsychological testing, true? 18 A. It states that on one of the FAQs, yes.
19 MR. LUPION: Object to the form. 19 Q. Other than that?
20 MR. SCHMIDT: I'll -- I'll join as well. 20 A. No.
21 THE WITNESS: The players had to agree to 21 Q. Do you know whether the National Hockey
22 this neuropsychological testing, yes. It was 22 League has at any time told its players that
23 a -- it was a -- it was a joint agreement from 23 repetitive head trauma could cause permanent
24 the players -- from the league and the Players' 24 brain damage?
25 Association that they had to agree so that we 25 A. During that time period?
Page 43 Page 45
1 can perform the neuropsychological testing on 1 Q. At any time.
2 them during training camp. 2 A. Can you repeat the question again?
3 MR. GIBBS: I'll move to strike because that 3 Q. Sure. Do you know whether the National
4 was nonresponsive. 4 Hockey League has at any time told its players
5 MR. SCHMIDT: I disagree. 5 that repetitive head trauma could cause
6 BY MR. GIBBS: 6 permanent brain damage?
7 Q. Is it true that -- that as far as you 7 MR. LUPION: Objection, asked and answered.
8 know, the only warnings the National Hockey 8 THE WITNESS: And again, it was -- it was --
9 League provided from 1997 to 2007 were in the 9 I've -- I've noticed -- I've seen it on the
10 form of the FAQs distributed to you and any 10 FAQs, so it has been posted for the players to
11 materials distributed vis-à-vis the neuropsych 11 see.
12 testing program? 12 BY MR. GIBBS:
13 MR. LUPION: Object to the form. 13 Q. That term, permanent brain damage?
14 THE WITNESS: I would say that, but I'd also 14 A. Yes.
15 say that on the -- the FAQs, it was marked NHL 15 MR. SCHMIDT: I just object that the FAQs
16 and NHLPA. It wasn't just the NHL. 16 speak for -- for themselves.
17 BY MR. GIBBS: 17 Counsel, we've been going about an
18 Q. Okay. But that has nothing to do with 18 hour. Could we take a short break?
19 what I'm asking you. 19 MR. GIBBS: Sure.
20 MR. SCHMIDT: Object to form. 20 MR. SCHMIDT: Thank you.
21 THE WITNESS: Then can you ask the question 21 THE VIDEOGRAPHER: The time is 10:00 o'clock.
22 again? 22 We are off the record.
23 BY MR. GIBBS: 23 (Whereupon, a short break was
24 Q. Sure. The only two warnings that you 24 taken.)
25 know that the NHL provided from 1997 to 2007 25 THE VIDEOGRAPHER: The time is 10:14. We're

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1 back on the record. 1 BY MR. GIBBS:
2 BY MR. GIBBS: 2 Q. What do you mean by working the door?
3 Q. Okay. I'd like to talk to you a little 3 A. When the players go on and off the ice,
4 bit about kind of how you as an athletic trainer 4 I would stand by the door and open the door in
5 do your job. Okay? 5 addition to -- so the players could come -- go
6 A. Uh-huh. 6 on and off the ice.
7 Q. And so most of my questions will -- 7 Q. And when was that?
8 will be general, and therefore, kind of 8 A. Probably '87 to '90-something. I don't
9 referring to your entire career as an athletic 9 recall how long.
10 trainer, but to the extent that things have 10 Q. And was that true of -- of your home
11 changed over the years, if you could indicate to 11 arena as well as all other arenas?
12 me that you're talking about a certain era when 12 A. Depended upon the arena. Home arena
13 answering my questions, I would appreciate it. 13 for sure. I'm not sure -- I mean, I don't
14 Okay? 14 recall any other arenas.
15 A. Okay. 15 Q. Are there any arenas today that your
16 Q. Where are you positioned during a 16 positioning would be such that you'd be working
17 National Hockey League game? 17 the door?
18 A. On the bench. 18 A. No.
19 Q. And what is the layout of the bench in 19 Q. And where is the team physician?
20 a National Hockey League game? Are you -- are 20 A. Depends on the venue. At home, he
21 you sitting next to players, behind players, in 21 stands right behind the bench. Outside -- the
22 front of players? 22 bench is enclosed, the posterior of the bench is
23 A. Standing behind players. 23 enclosed with a door, so the players exit on --
24 Q. So there is a literal bench that 24 into the locker room. There's a box there that
25 players sit on, true? 25 he stands, along with my assistant.
Page 47 Page 49
1 A. Correct. 1 On the road, it varies on the rink. He
2 Q. All right. And then behind that, 2 could stand right on the bench if -- in a -- in
3 there's an area where you and others are. 3 a doorway, observing the game, or if -- if
4 Who else is in that area behind the 4 he -- again, depends upon these -- the area. He
5 players? 5 might be right behind us on the bench or he
6 A. It's an elevated area. It varies on 6 might be in the locker room observing on -- on
7 height what -- what -- what rink we're in. 7 the television.
8 Myself, the coaches, and our head equipment 8 Q. And does the team physician travel with
9 manager. 9 the team?
10 Q. Where is the team physician during NHL 10 A. Currently, yes.
11 games? 11 Q. When did that begin?
12 A. In -- 12 A. Approximately five years ago, I
13 MR. SCHMIDT: Are you talking, just so we're 13 believe.
14 clear, currently or throughout time, because I 14 Q. During your entire tenure, has the head
15 think there was some variation on that. 15 athletic trainer traveled with the team?
16 MR. GIBBS: I don't know the answer to -- to 16 A. Yes.
17 that question. 17 Q. And is that true for preseason games,
18 MR. SCHMIDT: Well, on his prior testimony he 18 regular season games, as well as postseason
19 indicated -- 19 games?
20 THE WITNESS: Okay, let me clarify. On -- in 20 A. Yes.
21 the early days when we -- before we changed 21 Q. During your entire tenure, to the
22 stadiums, there was a period of time where I was 22 extent that you had an assistant, did the
23 not necessarily in front of the players, but I 23 assistant always travel with the team?
24 was working the door, so I had complete view of 24 A. No.
25 the ice. 25 Q. When did that happen?

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1 A. Approximately eight to ten years, 1 time, essentially, in your office?
2 approximately. I don't recall the exact amount 2 A. They may.
3 of years. 3 Q. For what purpose?
4 Q. And what about practice? Let's talk 4 A. Sometimes social, sometimes just
5 about kind of preseason practice. You all are 5 to -- during a game, sometimes just to cool down
6 getting ready to go down to the University of 6 and get away from everybody. Sometimes for
7 Notre Dame for your preseason practices. 7 treatment.
8 During those practices, where will you 8 Q. And what does that treatment consist
9 be stationed? 9 of?
10 A. Myself or my assistant will be on the 10 A. Depending upon the nature of the
11 bench. 11 condition.
12 Q. And is that true of every practice, 12 Q. Could be as simple as taping an ankle
13 either -- either the head athletic trainer or 13 to examining a knee for a torn ACL?
14 the assistant athletic trainer is -- is 14 A. Correct.
15 monitoring practice? 15 Q. Fair to say that -- that you develop a
16 A. It's required by the NHL and the NHLPA 16 relationship with these players?
17 that a certified athletic trainer be on -- 17 A. Correct.
18 present on the bench anytime the players are on 18 Q. And you are sort of their first line of
19 the ice. 19 defense in the prevention of injury as well as
20 Q. And is that true of -- of morning 20 the identification of injury?
21 skates as well as practices? 21 MR. LUPION: Object to the form.
22 A. Correct. Anytime a play -- players are 22 THE WITNESS: Correct.
23 on the ice, a certified athletic trainer must be 23 BY MR. GIBBS:
24 present on the bench. 24 Q. Do you keep in touch with players after
25 Q. And has that been true of your entire 25 they leave the team?
Page 51 Page 53
1 tenure? 1 A. Some players, yes. Not on a consistent
2 A. Not mandatory, but I've always -- 2 basis or not on a regular basis, but, you know,
3 myself or my assistant have always been on the 3 I may here and there.
4 bench anytime the players are on the ice. 4 Q. Do the Blackhawks host any alumni
5 Q. Okay. Your current home venue, do you 5 activities for former players, if you know?
6 have an office? 6 A. We have an alumni box in the United
7 A. Yes. 7 Center that alumni players are there at every
8 Q. And can you give me a little bit of 8 game.
9 understanding of kind of the -- the layout of 9 Q. And do you visit with those players on
10 that venue as it relates to your office and the 10 occasion?
11 players' dressing room? 11 A. I do not visit with them. They may
12 A. Starting from my office? 12 come down and visit with us.
13 Q. Sure. 13 Q. Are there any on-ice activities that
14 A. My office is approximately 8 feet from 14 former players participate in as far as alumni
15 the locker room. There's a small hallway that 15 games or anything like that?
16 the players walk down, turn, and go into the 16 A. I don't recall. There -- I know they
17 training room, which is where my office is. 17 do play a lot of games and they play -- I think
18 Then the ice is about -- the entrance 18 they play on a weekly basis, the -- they play
19 to the hallway to get to the ice is 19 together on a weekly basis or a monthly basis.
20 approximately like 5 feet, then there's a long 20 I'm not exactly sure, so yes.
21 corridor they walk down to get to the bench -- 21 Q. Are you aware of any former Chicago
22 not long corridor. It's probably about 20 feet, 22 Blackhawks currently suffering from any type of
23 maybe, and then they're on the bench. 23 brain damage?
24 Q. So before a game, at the intermissions, 24 A. Not to my firsthand knowledge.
25 and after the game, the players spend a lot of 25 Q. What do you mean by "not to my

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1 firsthand knowledge"? 1 caused by repetitive brain damage.
2 A. I mean, you hear things that, oh, this 2 Q. So you're not sure -- you're not sure
3 guy has problems. I don't know that -- I don't 3 whether the league ever told you or you're
4 know what it's the result of or I don't know if 4 saying --
5 it's a fact. 5 A. I'm not sure. We've had -- we've had
6 Q. Okay. And maybe -- maybe you 6 numerous seminars on concussions recently within
7 misunderstood my question. 7 the last recent years, and every year, we are --
8 I was just wondering if any of the guys 8 we -- we discuss -- we have a -- a conference on
9 has ever said to you, hey, I -- I have brain 9 concussions at our PHATS meetings, and I'm not
10 damage of any type? 10 sure if that -- those -- that was specifically
11 A. No. 11 brought up.
12 Q. We mentioned before the permanent brain 12 Q. Okay. As you sit there right now, you
13 damage that can result from repetitive head 13 just don't have a specif c recall of whether you
14 trauma. 14 have ever been told by the National Hockey
15 Do you know what types of brain damage 15 League that any of those conditions can be
16 can result from repetitive head trauma? 16 caused by repetitive head trauma. Is that a
17 MR. LUPION: Object to the form of the 17 fair characterization of your testimony?
18 question. 18 A. Yes. Right.
19 THE WITNESS: Not specifically. 19 Q. Have you ever warned a player on the
20 BY MR. GIBBS: 20 Chicago Blackhawks that repetitive head trauma
21 Q. Have you heard that Parkinson's disease 21 could lead to ALS, Parkinson's, Alzheimer's, or
22 can be caused by repetitive head trauma? 22 dementia?
23 MR. LUPION: Object to the form of the 23 A. That's outside my role. I -- I leave
24 question. 24 that -- I leave any conversation regarding
25 THE WITNESS: I've not heard that. 25 long-term effects of concussions up to our
Page 55 Page 57
1 BY MR. GIBBS: 1 physician.
2 Q. Have you heard that Alzheimer's disease 2 Q. Okay. So the answer to my question is
3 can be caused by repetitive head trauma? 3 no, you have never given that warning, true?
4 MR. LUPION: Same objection. 4 A. I have not.
5 THE WITNESS: I'm not familiar with that. 5 MR. SCHMIDT: Object to form, asked and
6 BY MR. GIBBS: 6 answered.
7 Q. Have you ever heard that dementia can 7 BY MR. GIBBS:
8 be caused by repetitive head trauma? 8 Q. True?
9 MR. LUPION: Same objection. 9 A. Correct, I have not.
10 THE WITNESS: Not that I recall. 10 Q. Okay.
11 BY MR. GIBBS: 11 A. I leave that to a doctor or physicians.
12 Q. Have you ever heard that ALS, or Lou 12 Q. Have you ever been present when the
13 Gehrig's disease, can be caused by repetitive 13 team doctor has told a Chicago Blackhawks player
14 head trauma? 14 that repetitive head trauma could lead to
15 MR. LUPION: Same objection. 15 Parkinson's, Alzheimer's, ALS, or dementia?
16 THE WITNESS: I do not recall. 16 MR. LUPION: Object to the form.
17 BY MR. GIBBS: 17 THE WITNESS: Meetings regarding those issues
18 Q. Fair to say that you have never been 18 are -- are done privately and I do not -- I'm
19 told by the National Hockey League that 19 not in attendance.
20 repetitive head trauma can lead to dementia, 20 BY MR. GIBBS:
21 Parkinson's, Alzheimer's, or ALS? 21 Q. So -- so you have not been present to
22 A. We may have had -- brought that up in 22 hear any of those, correct?
23 one of our seminars. I don't recall 23 A. Correct. That's outside my role.
24 specifically re- -- discussing -- I mean 24 Q. Have you ever been present when any
25 discussing that those particular conditions are 25 member of the Blackhawks organization, coaches,

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1 general managers, team executives, have told 1 examined, demonstrating the presence of CTE?
2 players that repetitive head trauma could lead 2 MR. LUPION: Objection.
3 to Parkinson's, Alzheimer's, ALS, or dementia? 3 THE WITNESS: I may have heard that, but I
4 A. Not to my knowledge. 4 don't recall.
5 Q. What is your understanding of chronic 5 BY MR. GIBBS:
6 traumatic encephalopathy? 6 Q. And that's really what I'm wondering.
7 A. I don't have a comment. 7 I mean, you remember reading about Duerson's CTE
8 Q. Have you ever heard of CTE? 8 findings.
9 A. I've heard of it, yes. 9 Do you remember anything about
10 Q. In what circumstances have you heard of 10 Boogaard's, Rypien's, or Belak's CTE findings?
11 CTE? 11 A. No.
12 A. Just the literature out there 12 Q. Do you remember reading about Junior
13 that's -- that's -- that talks about it. I've 13 Seau's CTE findings?
14 not investigated myself, personally. 14 A. No.
15 Q. Are you a Bears fan? 15 Q. You were Steve Montador's athletic
16 A. Not really. I mean, I follow them, but 16 trainer for period of time?
17 I'm not a Bears fan. 17 A. Uh-huh, yes.
18 Q. You know who Dave Duerson is? 18 Q. How long were you his athletic trainer,
19 A. Yes, I do. 19 if you recall?
20 Q. Do you understand that Dave Duerson 20 A. I believe approximately a year and a
21 shot himself in the chest in 2011? 21 half to two years.
22 A. Yes. 22 Q. And have you heard that subsequent to
23 Q. And you understand that subsequent to 23 his death, his brain was examined and it
24 that, his brain on postmortem neuropathological 24 demonstrated CTE?
25 study demonstrated CTE? 25 A. I don't know if I'd heard that it
Page 59 Page 61
1 A. That's what it states, but the 1 was -- that it demonstrates CTE, but I know that
2 circumstance -- circumstances that arise -- that 2 he was being examined, so I haven't really
3 brings it to that, I don't really know what they 3 heard -- read the results --
4 were. 4 Q. You weren't aware of the results?
5 Q. Okay. All I'm saying is you read the 5 A. No.
6 newspaper? 6 Q. At any time, has anyone from the
7 A. Yes. 7 National Hockey League made any statement to you
8 Q. And it stated that Dave Duerson had 8 regarding CTE?
9 CTE? 9 A. No.
10 A. It didn't state the causes, but yes. 10 Q. You mentioned some literature that
11 Q. And earlier that year in 2011, it was 11 might be out there regarding CTE.
12 reported that Bob Probert's brain demonstrated 12 Have you read any medical journal
13 CTE on neuropathological postmortem examination. 13 related to CTE?
14 Did you hear that at the time? 14 A. Not specifically. I may have read
15 A. I may have. I don't recall. 15 articles regarding it, but I don't recall the
16 Q. Before that time, had you ever heard of 16 specific article and the specific information
17 any former NHL or NFL players whose brains 17 that it was regarding that CTE.
18 demonstrated CTE on neuropathological postmortem 18 Q. I presume, then, that you have no
19 examination? 19 opinion whether or not CTE is caused by
20 A. Dave Duerson was probably the first one 20 repetitive head trauma?
21 that I've -- that I recall. 21 A. I have not seen the data that -- that
22 Q. Were you aware that subsequent to Dave 22 suggests the causes of the CTE, so I can't offer
23 Duerson's brain study results being released, 23 an opinion. I'm not a physician. I'm an
24 Wade Belak, Derek Boogaard, and Mark Rypien -- 24 athletic trainer, so I can't offer an opinion,
25 Rick Rypien, sorry, died and their brains were 25 based upon not being privy to the results.

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1 Q. Do you have any understanding as to the 1 we discuss it. Hypothetically, if a player has
2 reported symptoms of CTE? 2 concussion, there may be, you know, three other
3 A. I don't understand the question. 3 guys that may ask about what's going on there.
4 Q. Okay. Thank you for letting me know. 4 So we are constantly educating them,
5 Do you have any understanding as to how 5 letting them know that -- you know, what's going
6 the condition of CTE manifests itself in people 6 on with them, how we're treating them, how we're
7 who have suffered repetitive head trauma? 7 managing it, and that it's important for them to
8 A. I'm not a physician, so I -- I don't 8 let us to know symptoms.
9 know the symptoms of that and that's not -- it's 9 BY MR. GIBBS:
10 not a condition that -- you know, I deal with 10 Q. And so those posters tell players that
11 healthy male athletes, and it's not a condition 11 in their 40s and 50s, they may suffer from
12 that I deal with on a regular basis, so no. 12 memory loss, lack of impulse control, mood and
13 Q. But certainly, you care about your 13 behavioral issues, and potentially suicidality?
14 players and how they will be after they leave 14 MR. LUPION: Objection.
15 the game of hockey? 15 MR. SCHMIDT: Join.
16 A. Extremely, yes. 16 THE WITNESS: They don't say anything about
17 Q. And so if you knew that repetitive head 17 age. They -- they -- they warn about the -- the
18 trauma could cause later-in-life cognitive or 18 effects of -- of brain injury and the importance
19 mental health issues, that's something that you 19 of -- of -- they show the signs and symptoms and
20 would want those players to know about, true? 20 they warn about the importance to -- to report
21 A. Correct. And the information is out 21 any -- any of those to your trainers or your
22 there. 22 medical professionals.
23 Q. And if you knew that the symptoms of 23 BY MR. GIBBS:
24 CTE were things like a lack of impulse control, 24 Q. Okay. So -- so they do tell players
25 suicidality, aggression, depression, confusion, 25 that they may, in fact, suffer those things
Page 63 Page 65
1 memory loss, you would want those players to 1 later in life?
2 know that, true? 2 MR. SCHMIDT: Object to form.
3 MR. LUPION: Object to the form. 3 THE WITNESS: No. They just state that
4 THE WITNESS: Again, the information 4 they -- that these are things that we have to be
5 regarding the significant -- the effects of 5 aware of.
6 trauma -- chronic brain injuries is out there. 6 BY MR. GIBBS:
7 We have -- we have posters on the boards. We 7 Q. Things like suicidality?
8 have the FAQs that are -- that are posted in 8 A. No, of the conditions that -- that may
9 the -- in the locker room that are on the 9 cause -- may cause further damage -- repetitive
10 bulletin boards. But more -- and the -- the 10 may cause further problems down the road and
11 posters are posted both in the visiting locker 11 that these are the signs and symptoms that you
12 rooms and in the -- in the home locker rooms by 12 are to look for and that you have to make sure
13 every athletic trainer. 13 that your medical personnel are aware of those.
14 We've specifically -- we specifically 14 Q. And I guess I'm just -- I'm -- I'm
15 inform our players to -- you know, for proper 15 missing you.
16 care, you need to inform us of any conditions, 16 When you say signs and symptoms, you're
17 symptoms that you're having, and they -- we 17 talking about signs and symptoms of concussion?
18 can't -- we can't help you unless we know what's 18 A. Concussion, right.
19 going on. 19 Q. Okay. And I guess I'm talking about
20 So yes, there is -- I mean, written, 20 signs and symptoms of later-in-life cognitive or
21 yes, but there's -- there's tons of verbal stuff 21 mental health issues.
22 that we -- we do for these players all the time. 22 Does the -- do the posters warn of the
23 Specific incidents, I -- I -- I don't 23 risk of later-in-life cognitive or mental health
24 know, but we're -- we're -- I don't say on a 24 issues?
25 regular daily basis, but quite often, we're -- 25 MR. SCHMIDT: Just one minute. I'm just

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1 going to object on two grounds. One, the 1 MR. LUPION: Objection.
2 posters will speak for themselves as to the 2 THE WITNESS: Again, there -- I'm sure there
3 exact language, so if you have one, you can show 3 was conversation, not just in -- from the
4 it. And two, asked and answered. 4 Players' Association and the league. I -- I
5 Subject to that, if you -- you may 5 can't specifically state when, but it's always
6 answer. 6 been a -- an issue. Obviously -- and that's why
7 THE WITNESS: It specifically states that 7 we decided, the league and the PA decided to put
8 chronic brain injury may cause death, may cause 8 these studies in place. If it hadn't been
9 permanent disability, and may cause -- there's 9 talked about or hadn't been researched or hadn't
10 three things. I can't remember the third one. 10 been an issue, we wouldn't be doing these
11 BY MR. GIBBS: 11 things.
12 Q. So it doesn't talk about any of those 12 BY MR. GIBBS:
13 signs or symptoms like suicidality, mood and 13 Q. I understand what -- what you presume
14 behavioral issues, forgetfulness, lack of 14 was happening, but you don't know -- you, Mike
15 impulse control, true? 15 Gapski, don't know of any warnings prior to
16 MR. LUPION: Objection to form, assumes facts 16 those FAQs, true?
17 not in evidence. 17 MR. SCHMIDT: Object to form.
18 THE WITNESS: It doesn't specifically state 18 THE WITNESS: I don't recall.
19 that. It -- it states that chronic brain trauma 19 BY MR. GIBBS:
20 could -- could be -- can cause problems down the 20 Q. During a National Hockey League game,
21 road. 21 what are the mechanisms of injury that can
22 BY MR. GIBBS: 22 affect the head?
23 Q. Does that concern you? 23 A. The -- I mean, the -- a stick to the
24 A. Does that concern me? 24 head, shoulder to the head, head to the boards,
25 MR. LUPION: Objection. Does what concern 25 falling, bumping your head, body checking. It
Page 67 Page 69
1 him? 1 could be -- there's -- there's numerous things.
2 BY MR. GIBBS: 2 I mean, if a player falls, he can get --
3 Q. That your players may later in life be 3 accidentally get kicked in the head. He can run
4 suffering from permanent brain damage as a 4 into the goalpost. He can run into the
5 result of playing in the NHL. Does that concern 5 stanchion on the boards. I mean, hit a body for
6 you? 6 head zone, hit somebody's -- any part of
7 A. Yes, it concerns me. 7 anybody's body.
8 Q. And do you know whether it concerns the 8 Q. Fights?
9 NHL? 9 A. Fights would be -- can be, possibly.
10 A. I'm sure, yes, it does, because I think 10 Q. After two players drop the gloves and
11 if it didn't concern the NHL and the NHLPA, 11 engage in a fight, most of the time, those two
12 these warnings wouldn't be posted in the locker 12 players are taken to the penalty box, correct?
13 rooms. It wouldn't be posted in the FAQs. 13 A. Correct.
14 Verbally, they wouldn't be -- this information 14 Q. Do you have any way to assess a player
15 wouldn't be -- wouldn't be disseminated. 15 for symptoms of concussive brain trauma
16 Conferences wouldn't be held on a yearly basis. 16 following a fight while that player is in the
17 Research wouldn't be done on a -- on a -- on an 17 penalty box?
18 ongoing basis. So yes, I do think that we're 18 A. Signs, not symptoms.
19 making a concerted effort to make the players 19 Q. Exactly, and that's why I said symptoms
20 aware and -- and make the medical teams aware 20 and not signs.
21 of -- of -- of proper care. 21 You cannot assess a player for symptoms
22 Q. And as far as you know, the first time 22 of concussive brain trauma following a fight
23 that that was done was the FAQs, correct? 23 while that player is in the penalty box, true?
24 MR. SCHMIDT: Object to form. I think it 24 A. Correct.
25 misstates the testimony. 25 Q. And neither can your assistant athletic

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1 trainer? 1 to put them back in the game or not.
2 A. Correct. 2 Q. Okay. And -- and you've seen where a
3 Q. Or any team physician? 3 coach has decided to keep the player in the game
4 A. Correct. 4 after that?
5 Q. Or any medical personnel associated 5 A. Correct.
6 with the team? 6 Q. In those circumstances, that player
7 A. Correct. 7 cannot be assessed for symptoms of concussive
8 Q. That player ordinarily is assessed how 8 brain trauma while remaining in the game?
9 long of a penalty? 9 MR. SCHMIDT: Object to form.
10 A. Five minutes. 10 THE WITNESS: That's incorrect, because they
11 Q. And upon completion of those five 11 can be assessed, because once the -- once the --
12 minutes, that player returns to the ice? 12 once the penalty's over, they come to the bench.
13 A. Yes. 13 If the coach decides not to put them on the
14 Q. And continues to play in an NHL game? 14 bench, if -- if it's necessary, then we can
15 A. Possibly. 15 assess them on the bench, yes.
16 Q. And -- well, ordinarily? 16 BY MR. GIBBS:
17 A. It's -- that's a coaching decision. 17 Q. Okay. So the first instance that you
18 That's not my decision. 18 can assess, you, the athletic trainer can assess
19 Q. At least for -- for a period of time 19 a player for symptoms of concussion --
20 when -- when a player comes out of the penalty 20 concussive brain trauma following a fight is
21 box, he -- he plays in the game? 21 when they come over to the bench area, true?
22 A. No. When he -- when the players -- 22 A. True.
23 the -- the penalties -- when the penalty from 23
24 the fight is over, it's -- they get out at a 24
25 whistle, and then it's up to the coach to decide 25
Page 71 Page 73
1 where the player goes. 1
2 Q. There are certainly a lot of occasions 2
3 where a player continues to play after coming 3
4 out of the penalty box, true? 4
5 A. That's a coaching decision. I -- 5
6 Q. Is that true, though, in your -- 6
7 MR. SCHMIDT: Object to form. 7
8 THE WITNESS: It -- I've seen it, but it's -- 8
9 obviously, it's a -- it's not my decision to 9
10 make. 10
11 BY MR. GIBBS: 11
12 Q. You've seen over 2,000 NHL games? 12 Q. Because a sign of concussion is a blow
13 A. I have. 13 to the head, right?
14 Q. And so you've seen instances where a 14 MR. SCHMIDT: Object to form.
15 player drops the gloves, gets in a fight, goes 15 THE WITNESS: It can be.
16 to the penalty box, and comes back on the ice 16 BY MR. GIBBS:
17 and continues to play, correct? 17 Q. A sign of concussion is a blow to the
18 A. No. Again, they don't come on the ice 18 face, right?
19 and continue to play because once the 19 A. It can be.
20 whistle -- once -- the players are only allowed 20 Q. And if an NHL player has been involved
21 to come on the ice after a whistle's blown. 21 in a fight, more often than not, he has suffered
22 When the whistle's blown, they skate towards the 22 a blow to the head and/or a blow to the face?
23 bench because it's a stoppage of play, so they 23 A. Not necessarily. I mean, I've seen
24 skate towards the bench, and then that's a 24 numerous fights which is just -- which is a
25 coaching decision, up to them whether they want 25 wrestling match. I've seen numerous fights

612.338.3376
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1 where guys are throwing punches and they're 1
2 just -- they're -- they're -- they're not making 2
3 contact. I've seen numerous fights where guys 3
4 are throwing punches, they have body con- -- 4
5 they're -- they're hit -- punched in the bodies. 5
6 I've seen numerous fights where they -- they not 6
7 making -- they're not making contact with the 7
8 head. 8
9 Q. But you've also seen numerous fights 9
10 where players have received blows to the head 10
11 and/or face? 11
12 A. Correct. 12 Q. The league has never issued any
13 13 policies, procedures, or protocols specific to
14 14 how to deal with a player following a fight,
15 15 true?
16 16 A. I don't understand the question.
17 17 Q. Okay. We just went through your custom
18 18 and practice on how to deal with a player
19 19 following a fight, right?
20 20 A. Yes.
21 21 Q. The league has never issued any policy,
22 22 procedure, or protocol to you as an athletic
23 23 trainer on how to follow up with a player after
24 24 a fight?
25 25 MR. LUPION: Objection.
Page 75 Page 77
1 1 THE WITNESS: That's incorrect.
2 2 BY MR. GIBBS:
3 3 Q. Okay.
4 4 A. Because -- yes, it is -- if a player
5 5 shows signs on the ice of -- of some kind of
6 6 head trauma, then the officials are -- are aware
7 7 of the fact, and we are aware of the fact that
8 8 we can -- and that those players are then
9 9 removed from the ice for further evaluation.
10 10 Q. Okay. We might be getting crossed up a
11 11 little bit.
12 12 Has the league ever told you, Mike
13 13 Gapski, how you should deal with an NHL player
14 14 that has been involved in an on-ice fight?
15 15 MR. SCHMIDT: Object to form, asked and
16 16 answered.
17 17 THE WITNESS: Yes, because the -- the
18 18 protocol states that if a player is -- shows any
19 19 signs or symptoms of a -- of a fight, then we
20 20 must remove them from play -- we must remove
21 21 them for -- for evaluation.
22 22 BY MR. GIBBS:
23 23 Q. Okay. I guess what you're saying is
24 24 the same policies, procedures, and protocols
25 25 would apply to a player that's been in a fight

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1 as a player that has gotten a stick to the head. 1 (Whereupon, Gapski Deposition
2 Is that what you're saying? 2 Exhibit No. 3 was marked for
3 A. Not necessarily. I mean, it would 3 identification.)
4 be -- if the player got a stick to the head, 4 BY MR. GIBBS:
5 like, you have to understand the nature of 5 Q. Does Exhibit 3 refresh your
6 the -- I mean, if a guy gets tapped in the face 6 recollection as to a time that the league has
7 with a stick or gets -- gets a -- a blow, a 7 reached out to you regarding a player continuing
8 glancing blow to the head and has -- shows no 8 to play in a game following an observable sign
9 other signs, just because -- they probably would 9 or symptom of concussive brain trauma?
10 not be removed. 10 A. Yes.
11 Q. Okay. I'm not sure -- it's probably my 11 Q. Okay. I'm going to show you a publicly
12 question that doesn't make sense, but -- 12 available video, "Dennis Seidenberg hit from
13 MR. SCHMIDT: We'll stipulate that. 13 behind on Blackhawks Jonathan Toews," that's
14 BY MR. GIBBS: 14 available on YouTube, posted by HockeyTracker.
15 Q. -- other than a general concussion 15 MR. SCHMIDT: I'll just object to form.
16 protocol that the league provides, it provides 16 (Whereupon, a video was played.)
17 no additional protocol in how to deal with a 17 MR. GIBBS: Let's pause it right there.
18 player following a fight, true? 18 BY MR. GIBBS:
19 A. I -- that's something I -- I don't know 19 Q. This video purports to show, at least
20 that. 20 on the still shot that we're looking at right
21 Q. Well, they've never told you anything 21 now, Jonathan Toews and Blackhawks trainer Mike
22 about it? 22 Gapski.
23 A. They've never told me. 23 Is that you?
24 Q. All right. 24 A. It is.
25 A. They may -- might be an 25 Q. We just watched footage in which the
Page 79 Page 81
1 official -- they might have instructed the 1 player was struck from behind and forced into
2 officials. 2 the end boards, true?
3 Q. Have there been occasions where the 3 A. Correct.
4 league has followed up with you regarding a 4 Q. And that player was slow to get up?
5 player continuing to play after demonstrating a 5 A. Yes.
6 sign or symptom of concussive brain trauma? 6 Q. That player grasped his head?
7 A. The question is not clear. 7 A. I did not see that.
8 MR. SCHMIDT: I agree. 8 Q. On the video?
9 MR. GIBBS: Okay. Why don't we do this. 9 A. Oh. Can you play that again?
10 MR. SCHMIDT: Bill, do you want to go off the 10 MR. GIBBS: Let's go back.
11 record and get a couple minutes to get organized 11 MS. FAIA: From the beginning?
12 with this? 12 MR. GIBBS: Please.
13 MR. GIBBS: I'm good, unless you guys want to 13 (Whereupon, a video was played.)
14 take a quick break. 14 BY MR. GIBBS:
15 MR. SCHMIDT: We're fine. 15 Q. Did you see him grasp his head?
16 MR. GIBBS: All right. I'm going to mark 16 MR. SCHMIDT: Object to form.
17 this as -- 17 THE WITNESS: I did not see him grasp his
18 MR. SCHMIDT: Are you -- are you going to 18 head. I saw him -- his hand come over his body,
19 want to kill the lights for this or should we -- 19 and I don't know if he was looking to get up
20 no, actually, that looks okay. 20 or if he was -- if he grasped his head. I did
21 MR. GIBBS: Yeah. I'm going to mark this as 21 not really -- it was -- happened fast. I
22 Exhibit 3, and it is, for identification 22 didn't --
23 purposes, NHL2221370, and ask you to take a look 23 MR. GIBBS: Okay. Let's roll it.
24 at that. 24
25 25

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1 (Whereupon, a video was played.) 1 players that are placed on the Blackhawks
2 BY MR. GIBBS: 2 injured list?
3 3 A. That's unclear. I don't understand
4 4 what you mean.
5 5
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16 BY MR. GIBBS:
17 17 Q. Are you aware that --
18 18 A. If that were the case.
19 19 Q. -- that following this incident, it was
20 Q. And did he continue to play in that 20 reported that the Blackhawks informed the media
21 game? 21 that Jonathan Toews had sustained an upper body
22 A. He did. 22 injury?
23 Q. Did he then take a penalty? 23 A. Yes.
24 A. Yes. 24
25 Q. And do you know how long he remained in 25
Page 83 Page 85
1 the penalty box? 1
2 A. Two minutes. 2
3 3
4 4
5 5
6 6
7 7
8 8
9 9
10 10
11 MR. SCHMIDT: I'm going to object to form 11
12 at -- at this -- this time and object on the 12
13 basis of PMI and it's not something that, absent 13
14 an authorization -- if you have one, I'm -- I'm 14
15 happy to -- to share it with -- with you or -- 15
16 or Mr. -- let me rephrase that. 16
17 Mr. Gapski's happy to talk about the 17
18 care and treatment that was provided in -- in 18
19 this case if you have a signed authorization. 19
20 Counsel -- Counselor, do you have a 20
21 signed authorization from Mr. Toews? 21
22 MR. GIBBS: Let me rephrase my question. 22
23 MR. SCHMIDT: Okay. 23
24 BY MR. GIBBS: 24
25 Q. Do you have some knowledge as to 25

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18 18
19 19
20 20
21 21
22 22 MR. SCHMIDT: When you're done with the Toews
23 23 line of questioning, can we take a short break?
24 24 MR. GIBBS: Yeah. Let's take one now, yeah.
25 25 THE VIDEOGRAPHER: That's the end of Disk

612.338.3376
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1 No. 1. The time is 11:12. We are off the 1 (Whereupon, a video was played.)
2 record. 2 BY MR. GIBBS:
3 (Whereupon, a short break was 3 Q. That video --
4 taken.) 4 MR. SCHMIDT: Stop. Can you please turn on
5 THE VIDEOGRAPHER: This is the beginning of 5 the lights before we proceed with the question?
6 Disk No. 2. The time is 11:32. We are back on 6 BY MR. GIBBS:
7 the record. 7 Q. That video clip shows what?
8 MR. SCHMIDT: Before we go, I'd just like to 8 A. Shows Kris Versteeg falling into the
9 note we've been sitting here, waiting since 9 post of the net.
10 11:20 to go on. 10
11 Please proceed, Counselor. 11
12 BY MR. GIBBS: 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
22 22 MR. GIBBS: Let's do the next one.
23 23 (Whereupon, a video was played.)
24 24 MR. GIBBS: You can pause it.
25 25
Page 91 Page 93
1 1 BY MR. GIBBS:
2 2 Q. I've shown you a publicly available
3 3 video clip entitled, "Andrew Shaw Takes a Puck
4 4 in the Face on a Shawn Thornton Shot, Chicago
5 5 versus Boston."
6 6 Do you remember that play during the
7 7 2013 Stanley Cup finals?
8 8 MR. SCHMIDT: Object to form.
9 9 Go ahead.
10 10 THE WITNESS: Yes, I do.
11 11 BY MR. GIBBS:
12 12 Q. There was a member of the Blackhawks
13 Q. If we go back to our YouTube playlist, 13 training staff, I believe, that was on the ice
14 which we should have up for a second here -- or 14 with Andrew Shaw following that incident.
15 in a second here. 15 Was that you?
16 MR. GIBBS: Why don't we dim the lights, 16 A. Yes, it was.
17 Fallon, if we can? 17
18 MS. FAIA: Sure. 18
19 BY MR. GIBBS: 19
20 Q. I'm going to show you a video clip 20
21 that's publicly available on YouTube that's 21
22 entitled, "Gotta See It: Versteeg smashes face, 22
23 gets penalized." 23
24 MR. SCHMIDT: I'm going to object to the 24
25 form. 25

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1 1
2 2
3 3
4 4
5 5
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 MR. GIBBS: And could we go to the next one? 20
21 What happened there? No go? 21
22 (Whereupon, a video was played.) 22
23 BY MR. GIBBS: 23
24 Q. I'm showing you a publicly available 24
25 video entitled, "Corey Crawford stunned by puck. 25
Page 95 Page 97
1 Wild @ Blackhawks 5/3/2015." 1
2 Do you have any memory of that game or 2
3 any event surrounding Corey Crawford, the 3
4 Blackhawks goalie? 4
5 A. I do. 5
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13
14 14 Q. Are you aware that hockey operations
15 15 watches every NHL game?
16 16 A. Yes.
17 17 Q. And how are you aware of that?
18 18 A. It's known, obviously, because every
19 19 goal is reviewed, every -- every -- most plays
20 20 are reviewed, so I know that hockey operations
21 21 reviews. I don't know -- it didn't specifically
22 22 come out in a -- in a memo that hockey
23 23 operations watches every -- every game, but I
24 24 know that they do watch it.
25 25 Q. You mentioned before spotters.

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1 When was it that spotters were 1 Q. Have you ever seen that document
2 instituted in the NHL? 2 before?
3 A. I don't -- I believe last year 3 A. No.
4 officially. The year before, we also had -- I 4
5 believe the year before, we also had one. But 5
6 we've also -- in addition to just spotters, I 6
7 mean, that -- that was mandated, but, you know, 7
8 we -- we do our due diligence. I mean, if our 8
9 doctor is watching the play -- before the 9
10 spotters, if our doctor is watching the play, if 10
11 he sees something that we don't know, I can 11
12 signal to him or he would go and he would watch 12
13 a replay. 13
14 He usually, typically, any injury he 14
15 watches a replay, and if he suspects anything, 15
16 he would come out and -- and inform me of what 16
17 he thinks or whatever. He's -- we're -- we're 17
18 very good at -- and again, this was before -- 18
19 even before the spotters -- very good at -- at 19
20 watching the play and reviewing injuries during 20
21 the game to make sure that if it warrants, 21
22 somebody can be -- come out for evaluation. 22
23 23
24 24
25 25
Page 99 Page 101

1 1
2 2
3 3
4 4
5 5
6 6
7 7
8 8
9 9
10 10 Q. Okay. Do you think a spotter is a good
11 11 idea?
12 12 A. Do I think a spotter is a good idea? I
13 13 mean, it's -- it's a second -- it's a backup. I
14 BY MR. GIBBS: 14 mean, I think we do -- we -- we -- like --
15 Q. Okay. Did -- well, here, let me show 15 again, like I explained before, our doctors
16 you what we'll mark as Exhibit 4, which, for 16 watch the videos and -- and -- of any injury or
17 identification purposes, is NHL2112880. 17 any kind of cheap hit, bad hit, or whatever to
18 (Whereupon, Gapski Deposition 18 see if there's a potential here of that in
19 Exhibit No. 4 was marked for 19 addition to our spotters, so I think we did
20 identification.) 20 our -- in terms of the Blackhawks organization,
21 MR. SCHMIDT: Thank you. 21 we did our -- a good job of due diligence in
22 BY MR. GIBBS: 22 terms of reviewing plays to make sure that the
23 Q. Have you ever seen that document 23 safety and the -- and the health of the players
24 before? 24 was -- was -- was -- was taken care of.
25 A. I'm sorry? 25 Q. Do you think that the spotter should be

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1 an independent spotter? 1
2 A. Do I believe that -- I don't have a 2
3 belief on that. 3
4 4
5 5
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16 Q. Okay. Let me back up for a second.
17 17 How often do -- on average do you as
18 18 the head athletic trainer perform an assessment
19 19 on an NHL player for symptoms of concussive
20 20 brain trauma?
21 21 A. That varies from year to year. I mean,
22 22 there's -- I mean, we've had years where we've
23 23 had, you know, maybe thirteen, and we've had
24 24 years where we've had three. So it -- it varies
25 25 on a season by season, game by game. I -- I
Page 103 Page 105

1 1 can't give you an exact number or even a close
2 2 number. It just -- it's all dependent.
3 3 Q. And you understand I'm saying
4 4 assessment, not diagnosis?
5 5 A. Yes.
6 6 Q. Okay. So you've given me a range of
7 7 three times a year to thirteen times a year?
8 8 A. Well, again, I -- I -- that all varies
9 9 by the nature of the -- the hits, the nature of
10 10 the game, so I -- I can't give you a -- a true
11 11 number.
12 12 Q. Has that range changed over the years?
13 13 A. Yeah. Again, it changes on a
14 14 year-to-year basis, based upon the nature of the
15 15 games.
16 16 Q. And have you noticed any trends in your
17 17 28 years?
18 18 A. No.
19 19 MR. SCHMIDT: I guess object to form. I'm
20 20 not sure I totally understand, but go ahead.
21 21 THE WITNESS: Again -- again, that varies
22 22 from year to year, so I don't pay attention to
23 23 what -- what happens on -- with other teams.
24 24 All I care about is the care -- is the -- the
25 25 protection and care of our players, so no, I

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1 don't notice a pattern because it's -- it 1 player has demonstrated signs of concussion?
2 just -- again, it varies from year to year, team 2 A. Correct.
3 to team, and style of game. 3 Q. Okay. Once a player demonstrates signs
4 BY MR. GIBBS: 4 of concussion, you perform an assessment to
5 5 determine whether that player is suffering from
6 6 the symptoms associated with concussion, true?
7 7 A. That player would probably be removed,
8 8 because that would be during a game, would be
9 9 removed at that point in time and be
10 10 automatically assessed by our physician.
11 11 Q. That player should be removed, true?
13 BY MR. GIBBS: 13 THE WITNESS: No. They are removed.
14 Q. Okay. There's a difference between a 14 BY MR. GIBBS:
15 player being assessed for concussion and 15 Q. And they should be?
16 diagnosed with concussion, true? 16 A. Correct.
17 A. I don't diagnose, yes. 17 Q. A player that demonstrates a sign of
18 18 concussion should be removed to be assessed for
19 19 symptoms, true?
20 20 MR. SCHMIDT: Object to form of the question.
21 21 It's a new question.
22 22 THE WITNESS: Can you -- I'm sorry, can you
23 23 say that again.
24 24 BY MR. GIBBS:
25 25 Q. A player who has demonstrated signs of
Page 107 Page 109

1 1 concussion should be assessed for symptoms of
2 2 concussion, true?
4 4 THE WITNESS: Based upon the protocol, yes.
5 5 BY MR. GIBBS:
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13 Q. If you perform that assessment on a
14 14 player that has demonstrated signs of concussion
15 15 and in your opinion that player is not
16 16 demonstrating symptoms of concussion, do you
17 17 send that player to the physician for an
18 18 evaluation?
19 19 A. I guess I should clarify myself,
20 Q. All right. Let me give you an example. 20 because the -- typically, when you asked that
21 A player is hit in the head, goes to the ground, 21 question, you were talking about the duration of
22 and clutches his head. That player demonstrates 22 my extent of my career. We kind of changed it
23 some instability and takes a while to get up off 23 from periods to periods to the whole thing.
24 the ice. 24 Currently, more so now, a player is
25 You would agree with me that that 25 removed from the ice and assessed. I don't

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1 typically do that anymore. That's -- that was 1
2 done maybe early on and then -- and removed from 2
3 play, but now the players are removed from the 3
4 ice and assessed. 4
5 Q. Okay. And that's an important 5 Q. Is it also true that it's common
6 clarification. 6 knowledge throughout the league that some
7 7 players will avoid the concussion protocol by
8 8 always saying they're fine?
9 9 MR. LUPION: Object to the form.
10 10 THE WITNESS: I don't think that's
11 11 necessarily true anymore. I think the players
12 12 have been warned enough by the league and by
13 13 their PA that they are to report all symptoms
14 14 and sign -- not sign -- not some signs but all
15 15 symptoms to their -- to a medical staff so then
16 16 they can -- for proper care.
17 17 BY MR. GIBBS:
18 18 Q. When did that change?
19 19 A. It's -- it's player variable. It's --
20 20 it's dependent upon the player. I mean, some
21 21 players will come and tell you right away and
22 22 some players will try and hide things, but it's
23 23 our job in our educated opinion and evaluation
24 24 to -- to watch the play, see what the -- see the
25 25 signs are, know your players. Like you talked
Page 111 Page 113

1 1 about originally, the relationship you develop
2 2 with the players, so we know our players and so
3 3 we have a rapport with them and we can -- we
4 4 know that, okay, in the old days, okay, I see,
5 5
6 6
7 7
8 8
9 9
10 10
11 11
12 12
13 13 THE WITNESS: -- goes into the boards
14 14 flailing and comes off the ice, I may say -- go
15 15 up to them and do an evaluation and they say,
16 16 hey, Gapper, I'm just -- I'm just trying to draw
17 17 a penalty, so that's where I would do my
18 18 evaluation, finding out that the player is just
19 19 looking to draw a penalty, and it's happened
20 20 throughout my 28 years.
21 21 BY MR. GIBBS:
22 22 Q. And there's also guys that have been
23 23 concussed that have said to you I'm fine?
25 25 THE WITNESS: There may have. I don't

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1 know -- I mean, I can't state any player that's 1 THE WITNESS: Can you repeat the question
2 done that or nor I do remember that happening. 2 again.
3 BY MR. GIBBS: 3 BY MR. GIBBS:
4 4 Q. Sure. In the olden days, '87 to 2002,
5 5 a physician's evaluation of a player for
6 6 concussion was documented in writing?
7 7 A. Partially true in that a physician --
8 8 we had a report that was written -- was written
9 9 by them, but also at that time, I don't remember
10 10 the year, but we did have a computerized system
11 11 that was in place.
12 12 Q. Okay. And then at some point, it
13 13 transitioned to a computerized system?
14 14 A. It was early on, not -- not after 2002.
15 15 It was way prior to 2002. I don't remember the
16 16 exact year. It can really be -- it can
17 17 be the -- probably the early '90s. We had
18 18 another computerized program which all injuries
19 19 were entered also.
20 20 Q. And was that league wide or Chicago
21 21 Blackhawks specific?
22 22 A. League wide.
23 23 Q. And the electronic medical record is
24 24 still in place today; in other words, all
25 25 encounters are entered into the electronic
Page 115 Page 117

1 1 medical record?
2 2 A. Today. However, this -- this -- this
3 3 system is different than the one we previously
4 4 used.
5 5 Q. Right. It's a new system, but it's
6 6 still electronic?
7 7 A. Yes.
8 8 Q. Now, can you as head athletic trainer
9 9 look at a player's electronic medical record and
10 10 determine how many times that player has been
11 11 diagnosed with a concussion?
12 12 A. That -- that player's -- a
13 13 hundred percent of their records would be
14 14 accessible.
15 15 Q. So yes?
16 16 A. Yes.
17 17 Q. Can you look at the electronic --
18 18 A. Well --
19 19 Q. Go ahead.
20 Q. In the old days, let's say the first 20 A. Excuse me. I only have records up to
21 probably 15 years of your career, that 21 the point when we -- he enters the NHL. I would
22 documentation was pencil and paper? 22 not have records of any injury -- any injuries
23 MR. SCHMIDT: Object to form. You're talking 23 prior to that time.
24 what years exactly, '87 to 2002? 24 Q. Got it.
25 MR. GIBBS: '87 to 2002, yeah. 25 But you, in the electronic medical

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1 records, should have access to every time that 1 Okay?
2 that player has been diagnosed with a concussion 2 A. Okay.
3 during his NHL career? 3 Q. The instructions that you, Mike Gapski,
4 A. Everything that's recorded is -- would 4 receives and has received from the NHL --
5 be on that system. 5 A. Uh-huh.
6 Q. Would you have access to every time 6 Q. -- concerning multiple concussions
7 that that player was evaluated by a physician 7 comes in the form of posters, FAQ pamphlets, and
8 for concussion separate and apart from the 8 videos, and that's it, true?
9 number of times that player was diagnosed with 9 MR. SCHMIDT: Object to form, asked and
10 concussion? 10 answered. The witness gave a much more thorough
11 MR. SCHMIDT: Object to form. 11 answer. You just didn't want to listen to it.
12 THE WITNESS: I -- I may have. I -- I don't 12 THE WITNESS: We would have the -- we would
13 know -- I don't recall. 13 have that -- those meetings in -- in --
14 BY MR. GIBBS: 14 BY MR. GIBBS:
15 Q. Has the league ever instructed you to 15 Q. And meetings? Okay.
16 provide any specific warnings to players with 16 A. Right, and meetings.
17 multiple concussions? 17 Q. Those four things --
18 A. Again, I mean, it goes back to the 18 MR. SCHMIDT: And the preseason physical
19 posters, the verbiage, I mean, the videos and 19 process as well where the players fill out
20 all that stuff. They -- they give that to me, 20 authorizations. The record speaks for itself.
21 and I, in turn, give that to the players or show 21 THE WITNESS: Right.
22 the players or post it, so yes, I guess you can 22 MR. SCHMIDT: I will say this is like the
23 say they have. 23 fifth time we've gone over the exact same line
24 Q. Okay. And the form of those 24 of questioning, so we can keep doing this if
25 instructions are in the form of posters and 25 this is how you want to spend your time.
Page 119 Page 121

1 videos? 1 MR. GIBBS: It's -- it's different.
2 MR. SCHMIDT: Object to form. 2 BY MR. GIBBS:
3 THE WITNESS: There's videos. They may be -- 3 Q. You have never counseled a player to
4 there's verbiage that comes out. There -- I 4 walk away from the game because of multiple
5 mean, we have, as I said before, these meetings 5 concussions; is that true?
6 that are offered by the PHATS in the summertime. 6 A. That's not my role.
7 Those concussion study meetings are put on by 7 Q. I'm not asking if it's your role.
8 the NHL and the NHLPA. They're -- they're 8 You've -- you've never done that?
9 not -- and they are mandatory for the -- for the 9 A. No, I've never --
10 trainers to come, so that's -- that's one. 10
11 The players know -- they sign the 11
12 documentation during training camp, know that 12
13 they -- that they have to undergo this -- this 13
14 continuous neuropsychological ad- -- testing 14
15 which they have to require -- sometimes have to 15
16 do a paper and pencil, sometimes have to do 16
17 written, sometimes -- now they're adding some 17
18 other things. The SCAT3, we have to do a 18
19 baseline, so they -- they have to sign off on 19
20 this so that we're allowed to do this. 20
21 So yes, there's -- there's numerous 21
22 ways that the players and we are informed that 22
23 the concussion issues are important. 23
24 BY MR. GIBBS: 24
25 Q. Okay. And all I'm focusing on is you. 25

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1 MR. SCHMIDT: Object to form, asked and 1
2 answered. 2
3 Go ahead, you're fine. 3
4 THE WITNESS: No. 4
5 BY MR. GIBBS: 5
6 Q. And the league has never told you to 6
7 counsel players in that regard? 7
8 MR. LUPION: Object to form. 8
9 THE WITNESS: Again, that's not my role, 9
10 right, so no. 10
11 BY MR. GIBBS: 11
12 Q. Have you ever been requested by the 12
13 league to weigh in on any rule changes? 13
14 A. I have not. There's a rules committee 14
15 that the NHL has that they are -- that's their 15
16 responsibility and role to -- to make any rule 16
17 changes or thing like -- anything like that. 17
18 18
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1 1 change the rules because all this stuff is
2 2 collectively bargained. We can't do anything.
3 Q. And have you had any conversations, 3 I mean, it's -- it's kind of a -- we can't do
4 direct conversations with anyone from the NHL 4 anything without the league and the PA agreeing
5 regarding the communications that they offer 5 to -- agreeing to it.
6 publicly in relation to head injury? 6 Q. How do you know that?
7 MR. SCHMIDT: Object to form. 7 A. Because we've -- we've tried a few
8 THE WITNESS: I don't understand the 8 things. I mean, the league has to be -- if
9 question. 9 you -- if we want to do something for a player,
10 MR. SCHMIDT: Nor do I. 10 it has to be -- like -- I don't even know how I
11 BY MR. GIBBS: 11 would say this. Like anything that we do for
12 Q. Any articles that are written, press 12 the players outside of the -- the realm of the
13 releases that are issued, statements that are 13 hockey thing has to be -- it has to be okayed by
14 made to the media, you've never had any 14 the NHLPA.
15 conversations with anyone from the NHL about how 15 Q. How do you know that?
16 those should be messaged, true? 16 A. Because we've had experience with --
17 A. I don't believe so. 17 with the things I -- I can't remember for
18 Q. And so you in your role are relying 18 instance, but there's a few instances where,
19 upon the league to monitor the information that 19 like, not allowed to do things because it's not
20 you are providing through the Injury 20 collectively bargained, as a team or as an
21 Surveillance Program and do what they believe is 21 individual.
22 necessary to effectuate rule change, rule 22 Q. And you have -- but you have no
23 enforcement, education of players, and 23 specific example?
24 communication with the public in order to ensure 24 A. I can't remember a specific injury. I
25 the players are safe, true? 25 mean, obviously, I've been around for a long
Page 127 Page 129

1 MR. LUPION: Objection to form. Bill, I 1 time and -- and --
2 think there was like six questions in there. 2 Q. Okay.
3 THE WITNESS: Yeah, I -- I -- again, you're 3 A. -- you know, I have to be careful what
4 kind of unclear on that. 4 I do because things -- or I -- or I know what I
5 BY MR. GIBBS: 5 can't do because that's not collectively
6 Q. Okay. You rely upon the league to 6 bargained.
7 interpret the data that you put into the Injury 7 Q. You as the head athletic trainer cannot
8 Surveillance Program to keep players safe? 8 change the rules of play, true?
9 MR. LUPION: Object to the form. 9 A. True.
10 MR. SCHMIDT: Join. 10 Q. You as a head athletic trainer cannot
11 THE WITNESS: Not necessarily, because I can 11 change the way that rules are enforced, true?
12 have my own form of education to the players in 12 A. Not directly.
13 our locker room in terms of reporting what's -- 13 Q. You as head athletic trainer cannot
14 what's going on to me and conversations in the 14 change the way that the league communicates with
15 locker room of -- regarding concussion, so it's 15 either the players or the public on the issue of
16 not just from the league. You know, we have -- 16 concussive head trauma directly?
17 yeah... 17 A. I don't think that's necessarily true.
18 BY MR. GIBBS: 18 I think if I approached them and asked them to
19 Q. You can't change a rule? 19 change, I think they would be willing to listen
20 A. No. The rule committee is the -- I'm 20 and maybe -- and do that. I don't say -- I
21 not -- the rule committee makes -- makes all the 21 wouldn't say no to that question.
22 recommendations, and that's a joint venture. 22 Q. Okay. But you haven't?
23 That's not just -- I mean, the rule committee 23 A. But I haven't.
24 consists of the NHL, NHLPA, board of governors, 24 Q. Okay. And -- and concussions is a
25 and they take all this information and they 25 concern to you because you care about these

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1 players? 1 A. Probably -- probably six or seven years
2 A. Correct. 2 ago. I think it was before we won the first
3 Q. And you care about these players' 3 Cup. I can't remember if it was before we won
4 health today? 4 that or after that.
5 A. All the time. 5 Q. And do you remember the context? In
6 Q. Tomorrow? 6 other words, were you at a PHATS meeting? Were
7 A. Correct. 7 you --
8 Q. And 10, 20, 30 years down the road? 8 A. We were at a PHATS meeting and it was
9 A. Correct. 9 the -- it was a post-meeting, so the PHATS
10 Q. And so you, in entering that data into 10 meeting had -- had completed and this was a --
11 the Injury Surveillance Program, are relying 11 this was a concussion discussion group that we
12 upon the league to do whatever it can to ensure 12 were discussing, obviously, concussion issues
13 that players are safe today, tomorrow, and 10, 13 with the players, the players' reps, the
14 20, 30 years down the line, true? 14 players' NHLPA reps, and the NHL and the
15 MR. LUPION: Objection. 15 athletic trainers and the Physicians Society.
16 THE WITNESS: No, not true exactly, because 16 Q. During that caucus, did the issue of
17 we have the ability to go outside that realm 17 later-in-life issues come up?
18 and -- and use our physician or myself to 18 A. I -- I don't recall.
19 counsel the players and to do -- and 19 Q. Did the issue of appropriate warnings
20 to -- things that we deem medically necessary. 20 to players in relation to permanent brain damage
21 BY MR. GIBBS: 21 come up?
22 Q. Now, you have been involved in directly 22 A. I can't recall that, either.
23 communicating with the league about graded 23 Q. Did the issue of multiple concussions
24 exercise progression and its utilization in 24 and the potential relationship to long-term
25 return-to-play decisions? 25 consequences come up?
Page 131 Page 133

1 A. Correct. 1 A. I -- I don't recall that, either.
2 Q. Okay. We will get into that after 2 MR. GIBBS: All right. Why don't we take
3 lunch. Okay? 3 some lunch, and 1:00 o'clock sound good?
4 A. Okay. 4 MR. SCHMIDT: One o'clock sounds great.
5 Q. But other than that, has Mike Gapski 5 MR. GIBBS: All right.
6 been involved in any other way in dealing with 6 THE VIDEOGRAPHER: The time is 12:27. We are
7 the league on a direct level regarding 7 off the record.
8 concussions? 8 (Whereupon, a short break was
9 A. I have and I -- and it was -- I -- at 9 taken.)
10 the PHATS meeting, there was a -- there was a -- 10 THE VIDEOGRAPHER: The time is 1:09. We're
11 there was a concussion meeting with myself, I 11 back on the record.
12 think another athletic trainer, and one team 12 BY MR. GIBBS:
13 physician, along with representatives from the 13 Q. Okay. We've been talking a lot about
14 NHL and the -- and the NHLPA. It was an 14 the protocol.
15 eight-hour -- I don't mean eight-hour. It was 15 A. Okay.
16 a -- it was a meeting, discussion concussions, 16 Q. And I want to show you what we will
17 and John Rizos was there, two NHLPA reps were 17 mark as Exhibit 5.
18 there, Paul Comper was there, Dr. Kutcher was 18 (Whereupon, Gapski Deposition
19 there. John -- did I say John Rizos? 19 Exhibit No. 5 was marked for
20 Q. Yeah. 20 identification.)
21 A. John Rizos, I think Dr. Aubry from the 21 MR. SCHMIDT: Thank you.
22 Ottawa Senators, and it was a concussion 22 BY MR. GIBBS:
23 discussion regarding the health of the players. 23
24 I don't remember the specific topics. 24
25 Q. Do you remember when that was? 25

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10 10 BY MR. GIBBS:
11 11 Q. Okay. And when was it that the
12 12 neuropsych testing came into the league, if you
13 13 remember?
14 14 A. I think it was '97.
15 15 Q. Okay.
16 16 A. That was the baseline test. That's --
17 17 the baseline requirement by the league that they
18 18 bargained for that was made mandatory by the NHL
19 19 and NHLP that they had to do because it was hard
20 20 to convince guys that didn't want to do the
21 21 baseline test, so they had to bargain for that.
22 22 So they were -- it was made mandatory by their
23 23 association and by the league that we need to
24 24 study -- we need to, you know, look into this
25 25 further and you're going to have to do these

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1 tests. 1 you by the National Hockey League?
2 Q. And so it was your understanding that 2 A. I can honestly say I don't know because
3 beginning in 1997, a baseline would be given to 3 we started in '97 with some sort of -- of
4 every -- a baseline neuropsych evaluation would 4 testing protocol requiring -- regarding the
5 be given to every player prior to the season? 5 management of concussions, so I don't know if it
6 A. Prior -- yes. 6 came out in memo form, came out by -- at our NHL
7 Q. And then in the presence of a 7 PA -- our NHL PHATS meetings that this was the
8 concussion diagnosis, that player must be 8 requirement or were kind of disseminated
9 retested to ensure that he had returned to 9 somehow. I -- I don't know. I can't remember.
10 baseline before resuming play? 10 Q. Okay. So when you received this memo
11 A. Correct. 11 in January of 2010, what'd you do with it?
12 Q. And the protocol related -- that was 12 A. Obviously, I read it.
13 issued January 8, 2010, was called the 13 Q. Okay.
14 Concussion Evaluation and Management protocol. 14 A. And then we followed it.
15 What was your understanding as to what 15 Q. Okay. Did it change the way that you
16 that was? 16 dealt with signs or symptoms of concussive head
17 A. That was to -- 17 trauma?
18 MR. SCHMIDT: Is there more to this document 18 A. No.
19 or is this just these two pages? 19 MR. LUPION: Can I just interject for a
20 MR. GIBBS: The protocol is a big -- is a big 20 second? Bill, are you talking about the
21 document. 21 document that's annexed to the memorandum or the
22 MR. SCHMIDT: Okay. Well, I'll just object 22 memorandum itself?
23 that this appears just to be a cover memo and 23 MR. GIBBS: Both.
24 not the protocol itself. Subject -- and that 24 MR. SCHMIDT: Okay. Because the memor- --
25 the document speaks for itself. 25 the document that's annexed to the memorandum is
Page 139 Page 141

1 Subject to that, if you understand the 1 not before the witness.
2 question, you may answer. 2 MR. GIBBS: Correct.
3 THE WITNESS: I'm sorry, can you -- 3 THE WITNESS: Okay. Can you explain it
4 BY MR. GIBBS: 4 again --
5 Q. Okay. Exhibit 6 -- 5 MR. SCHMIDT: Object to form, but please ask
6 A. Yes. 6 the question again.
7 Q. -- is a memorandum from Bill Daly and 7 BY MR. GIBBS:
8 Julie Grand to all NHL head athletic trainers, 8 Q. Did you -- did your receipt of this
9 correct? 9 memorandum, Exhibit 5, change the way that you
10 MR. LUPION: Exhibit 5? 10 did things?
11 MR. GIBBS: 5. Sorry. 11 A. Not the receipt of the memorandum.
12 THE WITNESS: Yes. 12 Q. Okay.
13 BY MR. GIBBS: 13 A. Of the protocol.
14 Q. And so you would have received this 14 Q. Okay. How did it change things --
15 memorandum back somewhere around January 8, 15 A. I'm sorry, no, it didn't. It just --
16 2010? 16 I'm sorry. We got it -- it didn't -- nothing in
17 A. Uh-huh, yes. 17 my course of treatment changed. The
18 Q. And attached to this memo was a, quote, 18 difference -- yeah, nothing during my treatment
19 comprehensive protocol governing all phases of 19 changed.
20 concussion evaluation and management in the 20 Q. Now, Exhibit 6, which, for the record,
21 National Hockey League? 21 is a Dallas Stars document, 0001315 --
22 A. Correct. 22 MR. SCHMIDT: Do you have a copy of that?
23 Q. As far as you know, was that the first 23 MR. GIBBS: Yes.
24 time that that type of protocol, a concussion 24 MR. SCHMIDT: Thank you.
25 evaluation and management protocol, was sent to 25

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1 (Whereupon, Gapski Deposition 1
2 Exhibit No. 6 was marked for 2
3 identification.) 3
4 MR. SCHMIDT: I'd ask you to take a moment 4
5 and read it. 5
6 THE WITNESS: Okay. 6
7 BY MR. GIBBS: 7
8 8
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6 6
7 7 Q. Are you aware that on March 2, 2011,
8 8 Alan Schwarz from The New York Times published
9 9 an article called "Hockey Brawler Paid Price,
10 10 With Brain Trauma" regarding Bob Probert and the
11 11 fact that his brain had demonstrated the
12 12 existence of chronic traumatic encephalopathy?
13 13 MR. SCHMIDT: I would just like to reflect
14 14 the article hasn't been presented to the
15 15 witness, but subject to that, if -- if you have
16 16 a recollection.
17 17 THE WITNESS: I -- I don't recall the
18 18 article. I recall something similar to that,
19 19 but I don't -- I don't typically respond to
20 20 anything the media does because I don't think
21 21 the media has all the facts. I think they --
22 22 they blow things out of proportion.
23 23 BY MR. GIBBS:
24 24 Q. But my question is: Do you recall some
25 25 changes being made in the protocol after the

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1 publication of Bob Probert's CTE findings? 1
2 A. I don't know if that specifically is 2
3 related, to be honest with you. I don't -- 3
4 Q. Do you remember that or not? 4
5 A. No, I don't. 5
6 Q. Okay. I'm going to show you what's 6
7 been marked as Exhibit 7, which, for purposes of 7
8 identification, is NHL1779308, and give you a 8
9 second to take a look at that. 9
14 BY MR. GIBBS: 14
15 15
16 16
17 17 Q. I'm going to show you a document that
18 18 we will mark as Exhibit 9 to your deposition,
19 19 which is NHL0545085, give you a second to review
20 20 that, and then ask you a couple questions about
21 21 it.
22 22 (Whereupon, Gapski Deposition
23 (Whereupon, Gapski Deposition 23 Exhibit No. 9 was marked for
24 Exhibit No. 8 was marked for 24 identification.)
25 identification.) 25 THE WITNESS: Okay.
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22 22 THE WITNESS: I believe I understood the
23 23 revisions.
24 24 BY MR. GIBBS:
25 25 Q. And what were they?

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1 A. Basically, they were -- they were -- it 1 BY MR. GIBBS:
2 was -- I'm pretty -- I'm -- for the most part, I 2 Q. Okay. You mentioned your situation.
3 think it was that the -- only physicians were 3 How does your situation differ from
4 allowed to do the SCAT2 and they weren't 4 your understanding of other clubs' situation?
5 allowing any athletic trainers to do the SCAT2. 5 MR. LUPION: Objection. What do you mean by
6 However, we are -- we are well versed and 6 situation?
7 trained in the SCAT2 through our education and 7 MR. SCHMIDT: Yeah, I don't understand the
8 through everything and through our evaluations 8 question. Object to form.
9 prior to this time. 9 If you -- if you understand, you can
10 So this is something that we would have 10 answer. If you don't, please ask for
11 done previously and -- and that tool is out 11 clarification.
12 there for -- the SCAT2 is a tool that's used -- 12 THE WITNESS: Can you clarify a little bit?
13 can be used by any athletic trainer for any 13 BY MR. GIBBS:
14 concussion and sport. 14 Q. When you were saying in your situation,
15 And the way the league originally came 15 it didn't much matter to you, what did you mean?
16 out, what they wanted the physicians to do that 16 A. Well, I have an assistant trainer that
17 solely and that -- and players had to get off 17 travels with me.
18 the bench for 15 minutes. Well, it wasn't 18 Q. Okay. And do you know whether all
19 feasible for an athletic trainer off the bench 19 teams in the National Hockey League have
20 for 15 minutes, so that's kind of what the 20 assistant trainers that travel with them?
21 argument was about. 21 A. I don't know that.
22 Q. And what side of that argument were you 22 Q. Are there differences in the ways, if
23 on? 23 you know, that different clubs' trainers
24 A. It didn't mat- -- I didn't -- I don't 24 evaluate concussions?
25 think it made a difference to me. I mean, 25 A. I can't answer that, either. Every
Page 151 Page 153

1 obviously, it was easier for the physicians to 1 concussion is different, every player is treated
2 do it because I wouldn't want to leave the 2 differently, every -- every situation is
3 bench. In my situation, we had myself and an 3 different, so to say you can put a blanket on --
4 assistant trainer at -- traveling at the time, 4 blanket statement on one, it's -- it's not
5 so it was -- I was impartial. 5 practical because every concussion we treat
6 6 differently and we treat it on an individual
7 7 basis, based upon their symptoms.
8 8 Q. Have you had conversations with any of
9 9 your colleagues in the National Hockey League in
10 10 which they have indicated that their evaluation
11 11 processes as it relates to concussions are
12 12 different than yours?
13 13 MR. LUPION: Objection. At any time?
14 Q. And I think you told me before that the 14 MR. GIBBS: Yeah.
15 athletic trainers develop a certain relationship 15 THE WITNESS: We're all talented enough to
16 with the players and an understanding of the 16 know what we do. We're all trained in this
17 players as well? 17 aspect. We all have our own way of evaluating.
18 A. Correct. 18 Again, each concussion is different, so we
19 Q. So you can understand why some of your 19 typically don't say -- don't compare notes. I
20 colleagues were frustrated that this was being 20 don't want somebody to know what I do. I
21 taken away from them? 21 don't -- and they don't want me to know what
22 MR. SCHMIDT: Object to form. 22 they do, typically. We may have a general
23 THE WITNESS: Yeah, I -- I'm 23 conversation on -- on what we do or how we
24 not -- that's -- I can't make that comment. I 24 handle things, but in terms of what exactly we
25 don't know what their opinion was. 25 do, again, you can't do that because each

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1 concussion is individual and we treat that on an 1 to different cities, we have conversations.
2 individual basis based upon the -- our findings. 2 We -- we go and we say -- obviously, say hi to
3 BY MR. GIBBS: 3 each other and maybe have a brief conversation
4 Q. So it's fair to say that you have not 4 about current issues or just general
5 had conversations with other trainers across the 5 conversation, and -- and that topic does come up
6 league regarding a marked variability across 6 periodically.
7 clubs as to how this injury is evaluated across 7 Q. And during those casual conversations
8 the league, true? 8 with other trainers in the National Hockey
9 MR. SCHMIDT: Object to form. Were you 9 League, have you ever had conversations with any
10 reading from something? 10 of them regarding CTE?
11 BY MR. GIBBS: 11 A. No.
12 Q. Just a question. 12 Q. Regarding any later-in-life cognitive
13 A. I just -- I just -- I'm -- can you 13 or mental health issues that any former NHL
14 state that again? 14 players are facing?
15 MR. SCHMIDT: Just for the record, it looked 15 A. Not to my knowledge.
16 like the witness was -- or the -- 16 Q. Regarding the warnings that could or
17 MR. GIBBS: Doesn't matter. 17 should be given by the National Hockey League to
18 MR. SCHMIDT: -- the lawyer was reading from 18 players?
19 something. 19 MR. SCHMIDT: Form.
20 MR. GIBBS: I can read from anything. 20 THE WITNESS: Not just in general
21 MR. SCHMIDT: If you were, I'd ask you to 21 conversation, no.
22 show it to the witness. 22 BY MR. GIBBS:
23 MR. GIBBS: Can you read the question back, 23 Q. And --
24 please. 24 A. Informal situations, no, we don't
25 25 discuss those. They're discussed formally.
Page 155 Page 157

1 (Whereupon, the record was read 1 Q. Okay. At PHATS?
2 as requested.) 2 A. At PHATS or -- yes.
3 MR. LUPION: Is that -- did you say market or 3 Q. I'm going to show you an article that
4 marked? 4 we'll mark as Exhibit 10 to your deposition.
5 MR. GIBBS: Marked, M-A-R-K-E-D. 5 (Whereupon, Gapski Deposition
6 THE WITNESS: And what do you mean -- what do 6 Exhibit No. 10 was marked for
7 you mean by that? 7 identification.)
8 BY MR. GIBBS: 8 MR. SCHMIDT: Thank you.
9 Q. If you don't understand it, just say I 9 MR. LUPION: Thanks.
10 don't understand it. 10 BY MR. GIBBS:
11 MR. SCHMIDT: Object to form of the question 11 Q. I'll give you a second to read it and
12 or instruction from -- 12 then I'll ask you a question.
13 THE WITNESS: Yeah, I -- I don't truly 13 A. Okay.
14 understand. I mean, we have conversation. 14 Q. You've had an opportunity to read
15 However, again, what -- what you do, you do, you 15 Exhibit 10 that I placed before you, which is a
16 do, you do, you do is all different, and how we 16 publicly available document reproduction of an
17 treat things, it -- we may just bring it up 17 article that appears to have been published
18 in convers- -- we may mention it in 18 October 20, 2014, in Business Insider entitled,
19 conversation, we may bring it up in 19 "Nine-Time NHL All-Star Jeremy Roenick Describes
20 conversation, but the actual -- the actual 20 Life After Concussions." Correct?
21 treatment is not usually talked about. 21 A. Correct.
22 BY MR. GIBBS: 22 Q. You were Roenick's trainer for how
23 Q. And -- and where is it that those 23 long?
24 conversations are held, at PHATS or other -- 24 A. I don't know exact years. From his
25 A. Maybe at PHATS. Maybe when we travel 25 rookie year till he was traded to Philadelphia.

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1 Q. And do you remember when his rookie 1 MR. SCHMIDT: Hold on. I'm going to have
2 year was? 2 to -- unless, Counselor, you have a medical
3 A. I think maybe '89, maybe. 3 authorization authorizing the witness to talk,
4 Q. The first sentence of this article 4 I -- I can't -- I'd instruct you not to disclose
5 reads: Former National Hockey League star 5 any private medical information about Mr. --
6 Jeremy Roenick says that age -- that at age 19, 6 Mr. Roenick.
7 he was knocked out of a game with a concussion 7 MR. GIBBS: Let -- let me strike the question
8 that caused him to lose consciousness for 8 and rephrase it.
9 15 minutes. 9 BY MR. GIBBS:
10 Do you remember that incident during 10 Q. Are you aware of instances in which
11 Jeremy Roenick's rookie year? 11 Chicago Blackhawks reported to the media that
12 MR. SCHMIDT: I just object to the form. 12 Jeremy Roenick was concussed?
13 There's -- this doesn't appear to be Jeremy -- 13 A. I can't remember, to be honest with
14 any quotations, but a summation by the -- by 14 you.
15 the author, but subject to that, you may answer. 15 Q. Okay. The second full paragraph on the
16 THE WITNESS: Okay. Again, please? 16 second page of this article reads: Like most of
17 BY MR. GIBBS: 17 his peers who played in the 1980s and '90s,
18 Q. Do you remember that incident? 18 Roenick was unaware of the long-term effects
19 A. I should have if this was really true. 19 concussions can have on athletes who suffer from
20 I mean, like, I would never have a player that 20 them, a group of symptoms that can include
21 had been knocked unconscious for 15 minutes not 21 memory loss and depression.
22 carried off in a stretcher and taken to the 22 My question to you is: Do you agree
23 hospital. That's not going to happen under my 23 that most players who played in the 1980s and
24 watch. So I -- I don't remember that particular 24 '90s were unaware of the long-term effects of
25 incident, but I -- I know for a fact that I 25 concussions?
Page 159 Page 161

1 would not allow a person to be unconscious for 1 MR. LUPION: Objection.
2 any duration of time not be taken to the 2 THE WITNESS: I can't answer for the early
3 hospital on a spine board and -- and be -- be 3 '80s because I was not there. And I -- and I
4 thoroughly checked out. 4 can't recall when the -- what -- when we started
5 5 to put down -- when we started to place the --
6 6 the FAQs regarding the -- regarding concussion.
7 7 I can't remember when those first came out,
8 8 so -- to issues warning about concussions.
9 9 THE COURT REPORTER: I'm sorry, can you say
10 10 that again.
11 11 THE WITNESS: I can't remember when -- when
12 12 we first start putting warnings and -- and FAQs
13 13 out -- not warnings, but first issuing memos to
14 14 players regarding effects of concussion.
15 15 BY MR. GIBBS:
16 16 Q. Prior to the issuance of FAQs, do you
17 17 believe that your players on the Chicago
18 18 Blackhawks were unaware of the long-term effects
19 19 concussions can have on athletes who suffer from
20 20 them?
21 21 MR. LUPION: Objection to form.
22 22 MR. SCHMIDT: Join in the objection,
23 23 especially to the extent it covered prior
24 24 testimony earlier in the day.
25 25 THE WITNESS: You're asking my opinion. I

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1 don't have an opinion on that. 1
2 BY MR. GIBBS: 2
3 Q. Okay. Have you ever had any 3
4 conversations with any of the guys that played 4
5 on Blackhawks teams from '87 through the 5
6 issuance of the FAQs in which they told you that 6
7 they were unaware of the long-term effects 7
8 concussions can have on them? 8
9 A. I don't believe so. 9
10 Q. On the third page, second paragraph, 10
11 the author writes that Roenick says that he 11
12 had -- that had he known during his playing days 12
13 what he knows now, he would have taken more time 13
14 off to heal from injuries. 14
15 My question to you is: If players are 15
16 aware of the long-term effects that concussions 16
17 can have on them, do you think that they would 17
18 be more candid in reporting symptoms of 18
19 concussion? 19
20 MR. LUPION: Objection. 20
21 MR. SCHMIDT: Join. 21
22 THE WITNESS: I can only answer that from -- 22
23 from my -- my tenure that we've always tried to 23
24 educate players on the value of -- of reporting 24
25 signs and symptoms so that we can give them 25
Page 163 Page 165

1 proper care. I don't know if that's true with 1
2 anybody else, but I -- I know that's, you know, 2
3 from -- from my -- my tenure that it's one -- 3
4 one of the things we've always been sure of is 4
5 to make sure that, you know, have them report 5
6 any -- any injuries, any -- whether it be knee, 6
7 arm, anything, any injuries and conditions or 7
8 symptoms to us so that we can -- we can give 8
9 them proper care and treatment. 9
10 BY MR. GIBBS: 10
11 Q. Have any players or former players on 11
12 the teams that you were the athletic trainer 12
13 ever told you that if they knew that concussions 13
14 can have long-term effects on them, they would 14
15 have been more candid with you in reporting 15
16 their symptoms of concussive brain trauma? 16
17 A. I don't believe so. 17
21 MR. GIBBS: The -- Exhibit 11 is NHL2195482. 21
22 MR. SCHMIDT: Thank you. 22
23 MR. LUPION: Thanks. 23
24 THE WITNESS: Do you want me to read the 24
25 whole thing? 25

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1 1
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6 6
7 7
8 8
9 9
10 10
11 Q. Did you have an understanding at that 11
12 time as to what types of brain damage could be 12
13 caused by concussions? 13
14 MR. SCHMIDT: Object. I think we've gone -- 14
15 went over this in -- in the morning, but -- but 15
16 subject to that, you can answer again. 16
17 THE WITNESS: I may. I don't recall, I mean, 17
18 in terms... 18
19 BY MR. GIBBS: 19
20 20
21 21
22 22
23 23
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Page 167 Page 169

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1 1 Q. Okay. And you're aware that NHL
2 2 players speak a variety of languages, six
3 3 predominantly?
4 4 A. Correct. But with that being said,
5 5 I've also stated earlier that these were sent
6 6 out to the players in terms of an e-mail form
7 7 and possibly through the -- via -- via mail.
8 8 Q. By you or by someone else?
9 9 A. By the NHLPA.
10 10 Q. Okay. How do you know that?
11 11 A. Because the -- the players told me.
12 12 Q. Okay. What'd they tell you?
13 13 A. That they've seen these before and they
14 14 just -- you know, they just -- they've --
15 15 they've seen them before.
16 16 Q. Okay. When you received this document
17 17 which been -- which has been marked as
18 18 Exhibit 11 to your deposition and posted Pages 2
19 19 and 3, some or all of the players came up to you
20 20 and said, Gapper, we've seen these before?
21 21 A. I don't know if that's that particular
22 22 one, but the -- the gist of the -- the memo
23 23 had -- did come to them in the mail.
24 24 Q. Okay. And who said that to you?
25 25 A. I couldn't recall.
Page 171 Page 173

1 1 MR. GIBBS: Okay. It's 2:03. Let's take a
2 2 break.
3 3 THE VIDEOGRAPHER: This is the end of Disk
4 4 No. 2. The time is 2:03. We are off the
5 5 record.
6 6 (Whereupon, a short break was
7 7 taken.)
8 8 THE VIDEOGRAPHER: This is the beginning of
9 9 Disk No. 3. The time is 2:25. We're back on
10 10 the record.
11 11 BY MR. GIBBS:
12 12 Q. Okay. We were talking a while ago
13 13 about assessments of players following fights.
14 14 A. Uh-huh.
15 15 Q. What I'd like to do is show you a clip
16 16 and then ask you a question about it. Okay?
17 17 A. Okay.
18 18 Q. While we're waiting for that to load,
19 19 just --
20 20 MR. SCHMIDT: Yeah, for the questions, I'd
21 21 like to have the lights on. I don't mind
22 22 if -- and I think that screen will get bright
23 23 enough once you warm it up.
24 24 BY MR. GIBBS:
25 25 Q. While we're waiting on that, I'm just

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1 going to -- a couple kind of random thoughts and 1
2 conver- -- 2
3 A. Sure. 3
4 Q. -- notes here that I have that we can 4
5 expedite things with. 5
6 Have you ever had any conversations 6
7 with any athletic trainers in other professional 7
8 sports regarding best practices for concussion 8
9 management? 9
10 A. No. 10
11 Q. Have you ever had any other 11
12 conversations with other athletic trainers in 12
13 collegiate sports regarding best practices in 13
14 concussion management? 14
15 A. Actually, I take that back, I should 15
16 say, because my former assistant is a -- is the 16
17 head trainer for USA Rugby. I think that'd be 17
18 considered a professional sport, so he -- 18
19 we've -- we've conversed about concussions. 19
20 Q. Okay. And who's that? What's his 20
21 name? 21
22 A. Mike Keating. 22
23 Q. And how long has Keating been an 23
24 athletic trainer for USA Rubgy, if you know? 24
25 A. Probably -- probably, I want to say, 25
Page 175 Page 177

1 between six and eight years. 1
2 Q. Have you ever had any conversations 2
3 with Mr. Keating regarding what, if any, 3
4 warnings USA Rubgy should be giving its players 4
5 related to the potential risk of long-term brain 5
6 damage as a result of repetitive head trauma? 6
7 A. No, we didn't. 7
8 MR. GIBBS: All right. Let's watch the clip. 8
9 (Whereupon, a video was played.) 9
10 BY MR. GIBBS: 10
11 Q. Okay. So that was -- 11
12 MR. GIBBS: If you could just go back, just 12
13 so I can see what it's called. 13
14 MS. FAIA: Okay. Sorry. 14
15 BY MR. GIBBS: 15
16 Q. That was a YouTube clip from 16
17 hockeyfights.com, Canucks versus Blackhawks, 17
18 March 29, 2009. 18
19 Do you remember that incident? 19
20 A. Vaguely. 20
21 21
22 22
23 23
24 24
25 25

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1 1 game, you just make yourself a note of a certain
2 2 time or a certain play and then ask the video
3 3 coach to pull it up for you?
4 4 A. For the most part, yes.
5 5
6 6
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Page 179 Page 181

1 Q. Okay. Got you. 1
2 Does the NHL have any specific protocol 2
3 as to how to assess or evaluate concussive brain 3
4 trauma following a multiple-person fight any 4
5 different than the normal protocol? 5
6 A. Not that I know of. 6
7 Q. And you mentioned reviewing video. 7
8 Do you sometimes watch a game after the 8
9 game's over and review it to see if players 9
10 have -- 10
11 A. I will watch a game. I will watch a 11
12 particular incident in a game, and most likely, 12
13 several times to make sure I'm -- I got my -- my 13
14 facts correct before I make a decision on what 14
15 to do or just to make sure that nothing had 15
16 happened. 16
17 Q. And does the NHL provide those incident 17
18 videos or does your video guy or how does that 18
19 work? 19
20 A. Our video coach. 20
21 Q. Okay. 21
22 A. I go in and I ask him, hey, could I see 22
23 this, hey, could I see that, show me this, show 23
24 me that. 24
25 Q. Okay. So during the course of the 25

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612.338.3376
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1 marked -- what we will mark as Exhibit 13 -- 1
2 MR. SCHMIDT: Thank you. 2
3 MR. GIBBS -- which is NHL1636164. 3
8 BY MR. GIBBS: 8
10 10 Exhibit No. 14 was marked for
11 11 identification.)
12 12 BY MR. GIBBS:
13 13 Q. Okay. I'm going to place before you
14 14 what I've marked as Exhibit 14, which is, for
15 15 sake of the record, marked Chicago
16 16 Blackhawks 9967.
17 17
18 18
19 19
20 20
21 21
22 22
23 23 Q. Okay. Other than this, have you
24 24 created any other documents related to the issue
25 25 of concussion?
Page 187 Page 189

1 1 A. No.
2 2 Q. You have not put together any pamphlets
3 3 for players on concussions, you yourself?
4 4 A. No.
5 5 Q. You have not created any -- any posters
6 6 for players, you yourself?
7 7 A. No.
8 8 Q. You have not put any mailings out to
9 9 players dealing with concussions?
10 10 A. (No audible response.)
11 11 Q. And you haven't created any videos
12 12 other than the training video that we just
13 13 referenced that would be given to players, true?
14 14 A. Correct.
15 15 Q. Any -- we mentioned videos before.
16 16 Any videos that were given to players
17 17 by yourself or created by the National Hockey
18 18 League?
19 19 A. Yes. I mean, there -- there's videos,
20 20 there's posters, there's --
21 21 Q. Okay. We'll --
22 22 A. -- there's verbals, yeah.
23 23 Q. Yeah. Any posters that you --
24 24 MR. SCHMIDT: Let -- let -- let the witness
25 25 continue.

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Page 190 Page 192

1 MR. GIBBS: Okay. 1 was just kind of a just a general Q&A of what we
2 BY MR. GIBBS: 2 do, so nothing significant would -- would ever
3 Q. Any -- let's start again. 3 come out of that.
4 Any videos that you gave to players 4 Q. Back when you were teaching at the
5 were created by the National Hockey League, 5 University of Illinois, did you teach
6 right? 6 specifically on concussions?
7 A. In conjunction with the National Hockey 7 A. Taught everything, yes.
8 League Players' Association. 8 Q. And any specific textbooks or materials
9 Q. Okay. And any posters that you put up 9 that you utilized in that teaching?
10 were created by the National Hockey League? 10 A. I don't recall. The -- the books that
11 A. Again, both organizations. 11 I was using for teaching were the same ones that
12 Q. And any FAQs that you put up were 12 I mentioned previous, The Scientific Principles
13 created, as it related to concussions, solely by 13 of Athletic Training, advanced first aid and
14 the National Hockey League? 14 CPR, and that -- that one other emergency
15 A. Again, not solely. As a -- as a joint 15 medicine -- that book that I can't recall the
16 group. 16 name of it.
17 Q. Okay. And other than what we've marked 17 Q. Okay. Now, when you had the hockey mom
18 as Exhibit 14, you haven't put together any 18 seminar on September 25, 2013, what -- what --
19 other documents that go through any protocols on 19 you know, what did you tell those moms about
20 returning players to play following concussion? 20 concussions?
21 A. With the exception of the survey that 21 A. I didn't do that part. The -- the --
22 we did, this would be the only one. 22 Beth Pieroth, our -- our neuropsychologist, did
23 Q. Good exception. Good -- yes, I agree 23 most of the speaking. I was there primarily for
24 with that. 24 a -- I was there primarily for Q&A. I did
25 Now, what about presentations? Through 25 discuss helmet -- they did have -- discuss
Page 191 Page 193

1 your illustrious career, I'm sure you've been 1 helmets a little bit, proper fitting, and we --
2 called on from time to time to give 2 that's -- that's kind of where my role was in
3 presentations on a variety of issues in athletic 3 that.
4 training? 4 Q. And did anyone question whether or not
5 A. On athletic training? 5 repetitive head trauma sustained in hockey could
6 Q. Generally. 6 lead to later-in-life cognitive or mental health
7 A. I mean, I taught at the University of 7 issues for their children?
8 Illinois, in addition to being the head trainer, 8 A. I don't recall that. That wasn't my
9 the athletic training courses, the advanced 9 part of the -- the seminar, so I don't recall
10 first aid CPR courses. 10 exactly what Beth had said.
11 I would imagine -- the only other one I 11 Q. It may have come up?
12 can remember that I -- that I did is I did a 12 A. It -- it may have come up. I don't
13 concussion seminar with our neuropsychologist 13 know.
14 for hockey moms, but I don't -- that's -- those 14 Q. Do you remember if CTE came up?
15 are the only other seminars that I know I would 15 A. I do not believe so.
16 have been part of. 16 Q. Beth Pieroth has been the Chicago
17 Q. Okay. 17 Blackhawks neuropsych since when?
18 A. Actually, if you're -- if you're 18 A. I believe '97.
19 talking about seminars with questions and 19 Q. And --
20 answers, we used to have -- we had a convention 20 A. She -- I think she was an assistant
21 that was held by the Blackhawks, and we were on 21 kind of in '97, and maybe '99, kind of took
22 a panel for -- I think we did it for two years. 22 over.
23 We were on a panel that we as -- we were up on 23
24 stage for a Q&A. No medical information was 24
25 disseminated, no -- no personal information. It 25

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1 1 A. Correct.
2 2 Q. Did Beth report back to you anything
3 3 about Dr. Robert Stern's presentation at that
4 4 symposium regarding CTE and late-life issues
5 5 following concussion?
6 6 A. I don't recall.
7 7 Q. Had you ever heard from any of your
8 8 colleagues that weren't in the playoffs about
9 9 Dr. Stern's presentation at that symposium
10 10 regarding CTE and late-life issues following
11 11 concussion?
12 12 A. I don't believe so.
14 14 Exhibit No. 16 was marked for
15 15 identification.)
16 16 BY MR. GIBBS:
17 17 Q. Show you what's been marked as
18 Q. Understood. 18 Exhibit 16 to your deposition, which is
19 MR. GIBBS: Exhibit 15 is Chicago 19 NHL1826622.
20 Blackhawks 10488. 20 MR. LUPION: Thank you.
21 (Whereupon, Gapski Deposition 21 BY MR. GIBBS:
22 Exhibit No. 15 was marked for 22 Q. On Page 1 of that document, it
23 identification.) 23 indicates that you were giving a presentation on
24 MR. GIBBS: Thank you. 24 the role of strength and conditioning preventing
25 MR. LUPION: Thank you. 25 injuries at a conference in August of 2008.
Page 195 Page 197

1 THE WITNESS: Okay. 1 Do you see that?
2 BY MR. GIBBS: 2 A. I do.
3 Q. This appears to be an e-mail from 3 Q. Do you have any memory of The Puck
4 Lauren Peterson to yourself and others in which 4 Stops Here conference?
5 she's attaching a memorandum from Bill Daly and 5 A. Unfortunately, I don't.
6 Julie Grand encouraging club medical staff, both 6 Q. I presume, then, you don't remember any
7 team physicians and trainers, to attend the 7 specifics about any presentations that were made
8 Sports Neuropsychology Society Symposium in May 8 either before or after your presentation?
9 of 2013. 9 A. I do not remember any of this, no. I
10 Do you remember, you know, getting that 10 don't -- to be honest, I don't even remember
11 e-mail? 11 being a part of this. They may have had me on
12 A. Uh-huh, yes, I do. 12 the thing, but I may have been not able to make
13 Q. And did you, in fact, attend the Sports 13 it. I don't remember.
14 Neuropsychology Society International Sports 14 Q. Okay. What is Second Impact Syndrome?
15 Concussion Symposium in 2013? 15 A. Second Impact Syndrome is believed to
16 A. I did not. We were in the playoffs at 16 be -- because from what I understand now, the
17 that time. Beth represented us, and if I'm not 17 literature is disputing that Second Impact
18 mistaking -- mistaken, I believe -- we have a 18 Syndrome -- that if a person -- if a player
19 part-time physical therapist that works for us. 19 returns to participation prior -- post a
20 I believe that he may have attended that. 20 concussion, that a second -- a second impact to
21 Q. Okay. So neither you nor your 21 the brain can potentially cause a more
22 assistant trainer attended that? 22 significant injury, more significant -- more
23 A. We weren't able to, yes, correct. 23 significant brain injury by, I believe, it's
24 Q. Okay. And I presume the same is true 24 cutting -- shutting down the supply of blood to
25 of Dr. Terry? 25 the brain.

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1 Q. And what is post-concussive syndrome? 1 been fined or warned by the National Hockey
2 A. It's a -- it's a condition which -- 2 League for failing to trigger the concussion
3 where lingering concussion-like symptoms would 3 protocol?
4 just hang around for an extended period of time. 4 A. I'm not.
5 Q. How long can post-concussion syndrome 5 Q. That might be -- whoops. Sorry. We're
6 last, in your experience? 6 not done yet.
7 A. In my experience, a couple months. I 7 We talked before about baseline
8 mean, from -- from my direct experience. 8 neuropsych testing that's done at the beginning
9 Q. Right. 9 of every year, correct?
10 A. I've -- I've known there's other 10 A. Uh-huh, correct.
11 issues, but from my direct experience -- excuse 11 Q. Is that, in your experience -- and then
12 me -- a couple months -- as much as a couple 12 subsequent follow-up neuropsych in order to
13 months, I shouldn't [sic] say. There's -- 13 clear someone.
14 there's no rhyme or reason when -- when they -- 14 Is that, in your experience, the ImPACT
15 when it sets in nor when it's over. 15 suite or something else?
16 Q. Now, you mentioned literature as it 16 A. Well, there -- there was -- depends
17 related to Second Impact Syndrome. 17 upon which time frame you're talking about.
18 Can you -- do you -- 18 Q. Can you walk me through the evolution?
19 A. I can't quote the -- no. 19 A. The first -- the first one was a paper
20 Q. -- remember where -- where you read 20 and pencil test that started in 1997. That took
21 that? 21 about -- each player about 40 minutes to -- to
22 A. I don't remember, but I do remember 22 take and it was given by the -- a
23 hearing about it. 23 neuropsychologist and their -- and their
24 Q. Okay. How about literature related to 24 technicians. Later on, I'm not sure what year
25 post-concussive syndrome, have you researched 25 it started, they were -- so that served as a
Page 199 Page 201

1 that issue much? 1 baseline for a number of years.
2 A. I've read about it. I can't remember 2 Subsequent now we have a -- they've
3 what I read and where I read about it. Again, 3 instituted the ImPACT test and that
4 you know, we do these series of -- of seminars 4 was -- everybody, every player was -- had to do
5 at these PHATS meetings. I get -- I get 5 a baseline ImPACT test. That lasted for
6 different journals and periodicals 6 about -- I can't remember in terms of years. It
7 regarding -- that are -- that -- that are for 7 lasted for a number of years as -- as their
8 athletic trainers that have any kind of -- that 8 form -- as that player's form of baseline.
9 may -- that have random conditions. They're not 9 And then now what we are doing is we're
10 specifically relating to concussion. It can be 10 rebaselining everybody again, and everybody has
11 anything that's involved with athletic training. 11 to be rebaselined with the ImPACT test on a
12 Q. What journals and periodicals are 12 three-year term. So every three years, the
13 there -- are there out there? 13 players have to be rebaselined.
14 A. There used to be Physician and -- The 14 And that's -- it's constantly evolving
15 Journal of Physician and Medicine. It's no 15 based upon the information they give -- they
16 longer available. American Journal of Sports 16 get. I mean, the whole concussion thing is
17 Medicine. But they're -- those two, primarily. 17 evolving. I mean, it's gone from -- you can
18 Q. And those are publications that you and 18 tell by my explanations that it's run a bunch of
19 most athletic trainers would subscribe to? 19 different gamuts in terms of like when the --
20 A. Right. And then we also get one from 20 as -- as people become more educated, things
21 the NATA on a monthly basis that's -- I don't 21 change and evolve, and we're to the point of
22 know what the name of it is called. It just 22 the -- now that we, you know, we're adding more
23 says NATA on it that has a series of other 23 tests or -- more tests.
24 articles related to athletic training. 24 And the other baseline we do is the
25 Q. Are you aware of any team ever having 25 ImPACT -- not the ImPACT, I'm sorry, the SCAT2

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1 test, and that was done last year and it's being 1 IN THE UNITED STATES DISTRICT COURT
2 done again this year. 2 NORTHERN DISTRICT OF ILLINOIS
3 Q. And actually SCAT3 now, too, right, on 3 EASTERN DIVISION
4 IN RE: NATIONAL HOCKEY
4 the iPad?
5 LEAGUE PLAYERS'
5 A. SCAT -- or SCAT3 on iPad, SCAT -- yeah,
6 CONCUSSION INJURY MDL No. 14-2551
6 SCAT3. 7 LITIGATION (SRN/JSM)
7 Q. Now, at some point, it looks like the 8
8 Blackhawks were -- were chosen to do a trial of 9 This Document Relates
9 another suite called Cog, C-O-G, Sport? 10 to: ALL ACTIONS
11
10 A. I -- unless that's the Axon test, I
12 I, MIKE GAPSKI, being first duly sworn,
11 don't know if it -- if it was the Cog suite. It
13 on oath say that I am the deponent in the
12 may have been, but again, that's the 14 aforesaid deposition taken on the 27th day of
13 responsibility of Beth. She would perform those 15 August, 2015; that I have read the foregoing
14 tests, and I don't think that worked out. 16 transcript of my deposition, consisting of
15 Q. Okay. 17 Pages 1 through 204 inclusive, and affix my
18 signature to same.
16 MR. GIBBS: All right. Why don't we take a
19 ______________________________
17 two-minute break.
MIKE GAPSKI
18 MR. SCHMIDT: Sure. 20
19 MR. GIBBS: And then that might be just about 21
20 it. Subscribed and sworn to
21 THE VIDEOGRAPHER: The time is 3:08. We're 22 before me this_____ day
of_______________, 2015.
22 off the record.
23
23 (Whereupon, a short break was
24
24 taken.) _______________________
25 THE VIDEOGRAPHER: The time is 3:21. We're 25 Notary Public
Page 203 Page 205

1 back on the record. 1 STATE OF ILLINOIS
2 MR. GIBBS: The final issue is that we are 2 SS:
3 going to figure out a way to create a hard copy 3 COUNTY OF C O O K
4 of the videos that we've shown you today and 4
5 those will be marked as Exhibit 17. There's an 5 I, VICKI L. D'ANTONIO, a Notary Public
6 objection to that. 6 within and for the County of Cook and State of
7 MR. SCHMIDT: Yeah. Just object to the form 7 Illinois, do hereby certify that heretofore,
8 of those exhibits, especially the commentary or 8 to-wit, on the 27th day of August 2015,
9 the titles or -- or the lack of foundation, but 9 personally appeared before me MIKE GAPSKI, a
10 subject to that, those are issues we can deal 10 witness in a certain cause now pending and
11 with down the road. 11 undetermined in the United States District
12 MR. GIBBS: Okay. So subject to that being 12 Court, Northern District of Illinois, Eastern
13 included in the record, I have no further 13 Division, In Re: National Hockey League Players'
14 questions for you at this time. 14 Concussion Injury Litigation.
15 MR. SCHMIDT: Thank you. 15 I further certify that the said MIKE
16 THE WITNESS: Okay. Thank you. 16 GAPSKI was by me first duly sworn to testify the
17 MR. GIBBS: Thank you for your time. 17 truth, the whole truth, and nothing but the
18 MR. SCHMIDT: We'll read and -- we'll read 18 truth in the cause aforesaid; that the testimony
19 and sign as well. Thank you very much. 19 then given by said witness was reported
20 Off the record. 20 stenographically by me in the presence of said
21 THE VIDEOGRAPHER: That's the end of the 21 witness and afterwards reduced to typewriting by
22 deposition. The time is 3:22. We're off the 22 Computer-Aided Transcription, and the foregoing
23 record. 23 is a true and correct transcript of the
24 (Whereupon, the deposition 24 testimony so given by said witness as aforesaid.
25 concluded at 3:22 p.m.) 25 I further certify that the signature to

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1 the foregoing deposition was reserved by counsel
2 for the respective parties.
3 I further certify that the taking of this
4 deposition was pursuant to notice and that there
5 were present at the deposition the attorneys
6 hereinbefore mentioned.
7 I further certify that I am not counsel
8 for nor in any way related to the parties to
9 this suit, nor am I in any way interested in the
10 outcome thereof.
11 IN TESTIMONY WHEREOF: I have hereunto
12 set my hand and affixed my notarial seal this
13 8th day of September, 2015.
14
15
16
____________________________________
17 NOTARY PUBLIC, COOK COUNTY, ILLINOIS
CSR LIC. NO. 84-004344
18
19
20
21
22
23
24
25

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46:9 49:15 183:4,10 23:4 25:10 201:5,8,24 162:9 3:12 5:18
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138:2,15 variability 180:2,11 133:16 89:17 91:5 45:17 56:5
151:16 154:6 187:17 137:20 watches 56:5 63:14
152:4 variable 189:12 142:14 97:15,23 89:17 90:9

612.338.3376
Page 233
91:5 98:6 witness 4:2 152:12 75:3 177:2 105:22 Zeis 142:13
104:22,22 6:7,8 16:19 153:15 177:18 106:2,2 zone 69:6
104:23,24 17:7,25 154:16,22 178:3 116:10,16 Zurich 16:25
110:25 18:19 31:1 155:6,13 writes 144:10 124:17,18
120:23 31:13 32:8 156:20 144:20 157:25 0
124:6,7 32:18 38:2 158:16 162:11 158:2,11 0001315
125:10 42:21 43:14 160:3 161:2 writing 116:6 159:6 141:21
128:7,7,16 43:21 44:8 161:11,25 written 26:16 181:24 0109607
133:13 45:8 47:20 162:22 26:17,20,22 182:6,21,21 147:4
134:16 52:22 54:19 163:24 63:20 116:8 182:23,24 084-004344
147:2 54:25 55:5 164:13 116:8 200:9,24 1:25
162:23 55:10,16 166:17 119:17 202:1,2
163:4 57:17 60:3 176:5 126:12 year-to-year 1
166:14 63:4 64:16 180:20 wrong 112:4 105:14 1 4:9 8:11,16
172:20 65:3 66:7 182:14 wrote 21:21 yearly 28:7 90:1 196:22
174:19,19 66:18 68:2 186:7 wtg@corbo... 29:15 67:16 204:17
183:9 68:18 71:8 189:24 2:9 years 11:11 1:00 133:3
185:25 72:10 73:15 195:1 11:18 12:3 1:09 133:10
190:17 75:24 77:1 203:16 X 12:11,15 10 4:14 7:3
203:4 77:17 81:17 205:10,19 X 4:1,6 107:6 13:17,25 130:8,13
weekly 53:18 84:14 85:6 205:21,24 15:9 20:16 157:4,6,15
53:19 85:22 90:21 witness's Y 23:7 24:4 10:00 45:21
weigh 122:13 90:25 93:10 44:4 yeah 7:17 8:2 27:13,15 10:14 45:25
well-being 94:5 95:20 won 132:2,3 8:10 16:16 29:4 30:21 10036 3:17
151:9 99:13 103:9 wondering 19:12 35:25 32:13,20 10488 194:20
went 19:19 104:2 17:4 35:24 79:21 82:17 33:3,14 11 4:14 85:20
20:14,24 105:21 54:8 60:6 89:24,24 34:25 35:9 163:19,21
76:17 86:18 106:11 96:9 103:18 99:13 36:4 38:13 164:4 165:3
88:19,19 108:13,22 106:5 105:13 38:21 46:11 172:18
166:15 109:4 114:17 114:18 49:12 50:1 11:12 90:1
weren't 61:4 112:10 words 82:18 115:25 50:3 56:7 11:20 90:10
135:3 150:4 113:11,13 116:24 124:16 60:21 96:3 11:32 90:6
176:24 113:25 132:6 127:3,17 96:3 102:4 12 4:15
195:23 116:1 work 26:24 131:20 102:17 164:25
196:8 118:12 27:11 110:7 141:18 104:22,24 181:2,6
what'd 119:3 179:19 142:24 105:12,17 12:27 133:6
140:11 120:10,12 worked 151:23 110:7 13 4:15 186:1
172:12 120:21 202:14 152:7 113:20 186:5
WHEREOF 122:4,9 working 153:14 115:21,24 133 4:11
206:11 126:8 127:3 22:15,17 155:13 130:8,14 14 4:16
whistle 70:25 127:11 47:24 48:2 169:16,17 132:1 188:10,14
71:20 130:16 48:16 169:17 157:24 190:18
whistle's 134:8 works 33:20 170:14 175:1 14-2551 1:7
71:21,22 135:23 195:19 173:20 191:22 5:4 204:6
whoops 136:15 worry 111:22 182:23 201:1,6,7 142 4:12
200:5 139:3,12 wouldn't 189:22,23 201:12 146 4:12,13
wide 116:20 141:1,3 13:5 67:12 202:5 203:7 York 3:17,17 148 4:13
116:22 142:6,24 67:13,14,15 year 14:1,18 145:8 15 4:16
Wild 95:1 143:19 67:15,16,17 16:2 19:21 YouTube 115:21
WILLIAM 2:4 144:5 68:10 75:13 23:8,9 80:14 91:13 150:18,20
willing 145:15,17 129:21 27:11 29:12 91:21 158:9,21
129:19 146:13 151:2 56:7 59:11 175:16 194:19,22
window 29:3 147:18 176:25 60:20 98:3 157 4:14
wing 186:11 148:25 177:4,20 98:4,5 99:7 Z 16 4:17 149:7
186:21,23 149:22 wrestling 104:21,21 Z-E-I-S 196:14,18
wings 187:5 151:23 73:25 74:23 105:7,7,22 142:13 1600 26:11

612.338.3376
Page 234
161 1:18 5:8 175:18 3:08 202:21 139:15

163 4:14 2010 133:23 3:21 202:25 146:24
17 4:17,19 134:12,12 3:22 203:22 147:3
203:5 138:13 203:25 80 4:10
181 4:15 139:16 30 130:8,14 80s 161:3
186 4:15 140:11 31 182:5 81 24:3
188 4:16 147:24 312 2:8 82 27:3,21
19 100:6 2011 58:21 314 3:9 84-004344
158:6 59:11 33 2:5,15 206:17
194 4:16 142:22 333-3000 85 27:18,22
196 4:17 143:6,17 2:18 87 14:10,25
1976 19:22 144:3,17 346-3191 2:8 24:25 27:3
1980 24:2 145:7 3600 3:7 29:3 48:8
1980s 160:17 147:16 3800 2:16 115:24,25
160:23 149:4,7,17 116:4 162:5
1982 26:1,2 2013 93:7 4 89 158:3
27:1 182:5 4 4:11 28:9 8th 206:13
1987 14:2,3 192:18 99:16,19
24:2 25:10 195:9,15 149:4 9
28:18 29:21 2014 85:20 169:19,24
30:1,6 100:7 169:25
1997 14:19 157:18 170:15,18
41:11 43:9 2015 1:19 40 200:21
43:25 138:3 5:9 8:14,23 40s 64:11
200:20 204:15,22
205:8 5
2 206:13 5 4:11 51:20
2 4:10 8:21 203 4:17 133:17,19
9:2 85:8 204 204:17 139:10,11
90:6 144:9 211 3:6 141:9 143:7
145:7 168:5 212 3:18 169:19,24
168:8 169:2 21st 2:6 169:25
169:14,17 22 8:14 170:15,18
169:18 25 192:18 5/3/2015
170:21 259-2000 3:9 95:1
172:18 25th 8:23 50s 64:11
173:4 27th 1:19 5:9
2,000 71:12 204:14 6
2:03 173:1,4 205:8 6 4:12 7:1
2:25 173:9 28 11:11,18 139:5
20 51:22 13:25 96:3 141:20
130:8,14 105:17 142:2,12
157:18 113:20 60602 2:7
2000 15:11 29 96:3 612 2:18
42:5 175:18 63102 3:8
2000s 16:5
2002 115:24 3 7
115:25 3 4:10 79:22 7 4:12 146:7
116:4,14,15 80:2,5 85:8 146:11,15
2007 41:11 91:3 168:5 75 27:12
42:13 43:9 168:9 169:2 28:12 29:13
43:25 44:17 169:14,17
2008 196:25 169:18 8
2009 164:6 170:21 8 4:9,13
166:9 168:4 172:19 51:14
169:2 173:9 138:13

612.338.3376

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Confidential Pursuant to Protective Order - Deposition of Mike Gapski - 8/27/2015

In Re: National Hockey League Players' Concussion Injury Litigation

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