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June 15, 2022

Via Email

The Honorable Carolyn B. Maloney

The Honorable Raja Krishnamoorthi
Committee on Oversight and Reform
2157 Rayburn House Office Building
Washington, DC 20515-6143

Re: Request for testimony of Dan Snyder, co-owner of the

Washington Commanders

Dear Chairwoman Maloney and Chairman Krishnamoorthi:

I respectfully submit this letter in further response to your June 1, 2022 letter
requesting that my client Dan Snyder appear for a hearing on June 22, 2022. On June 6,
2022, I responded by letter to the Committee’s request to request additional information
about the scope of the Committee’s inquiry in light of ongoing investigations
encompassing substantially similar topics. I also stated that Mr. Snyder remains fully
willing to assist the Committee in its investigation, and expressed my hope that we could
find a mutually agreeable date on which Mr. Snyder would be able to provide testimony to
the Committee assuming that the concerns outlined below are addressed.

I appreciate that the Committee’s staff promptly responded to my letter and

were able to speak the next day regarding Mr. Snyder’s questions and concerns.
Regrettably, however, the Committee declined to provide the information reasonably
requested in the June 6 letter, or to provide assurances that would allay the concerns about
the hearing. The Committee also stated that it is not willing to consider changing the date
of the hearing, despite the fact that Mr. Snyder has a longstanding Commanders-related
business conflict and is out of the country on the first and only date the Committee has
proposed for the hearing. The Committee instead insisted on a yes-or-no response from
Mr. Snyder as to whether he would appear for the hearing at the appointed time. Although
Mr. Snyder remains willing to cooperate with the Committee—as he has done in the past—
for the reasons set forth below, he is unable to accept the Committee’s invitation to testify
at the scheduled hearing.
 The Honorable Carolyn B. Maloney
The Honorable Raja Krishnamoorthi -2-

As noted in my June 6 letter, the Attorneys General of the District of

Columbia and Maryland are currently conducting investigations into issues substantially
related to the matters the Committee has indicated that it may address at the planned
hearing. In addition, as the Committee is well aware, on behalf of the NFL, Mary Jo White
of Debevoise & Plimpton LLP is conducting a similar investigation, the results of which
the NFL has stated that it intends to make public. To better understand the potential overlap
between these investigations and the Committee’s request for testimony, and to ensure that
he could provide useful testimony in furtherance of the Committee’s stated goals, I
requested additional information regarding the proposed hearing, such as the materials and
matters that he would be expected to address.

During a June 7, 2022 phone call led by Chioma Chukwu, General Counsel
for the Committee, I was informed that the Committee was unwilling to accommodate any
of these reasonable requests. Specifically, although the Committee indicated that the
hearing would be “focused on” the historical workplace culture issues, I was informed that
the Committee would not provide any assurance that the questions directed to Mr. Snyder
would be limited to those issues, given the wide latitude granted to members to ask
questions beyond the topics identified by the Committee. The Committee also declined to
provide any additional information about the nature and scope of its investigation,
including the identity of any other witnesses that have testified about the team and/or my
client, whether any such witnesses have made allegations about the team and/or my client,
and the substance of any such allegations. The Committee likewise refused to provide
copies of documents that members of the Committee intend to question Mr. Snyder
about—a courtesy that I understand is often extended to witnesses at congressional
hearings.

I disagree with the Committee’s apparent view that these requests are
unacceptable and inappropriate, especially against the backdrop of what has occurred at
earlier hearings related to this matter. A prior witness publicly alleged for the first time—
despite declining to do so when given the opportunity on two occasions in a previous
investigation, and notwithstanding a lack of credible evidence to support her claim—that
Mr. Snyder engaged in misconduct toward her on a single specified occasion at least 14
years ago. In the more than four months since that public allegation was made, counsel for
the team have asked the Committee’s staff to provide basic information about that alleged
incident, such as when and where it supposedly occurred, and who else was present, so that
Mr. Snyder could have a reasonable opportunity to provide evidence rebutting the witness’s
allegations, which he denies. Yet the Committee’s staff has declined to provide any such
information. And of course, Mr. Snyder has no way of knowing what other non-public
allegations may have been made against him before this Committee. It goes against
fundamental notions of fairness and due process to decline to provide such basic
information that would enable a witness to defend himself or even respond fully during a
public hearing, particularly in light of pending investigations addressing similar
allegations.
 The Honorable Carolyn B. Maloney
The Honorable Raja Krishnamoorthi -3-

Moreover, with respect to the date of the proposed hearing, I explained to

Ms. Chukwu that, in addition to my own scheduling challenges, Mr. Snyder has
longstanding plans to be out of the country on business matters on that date. Yet I was
informed that, despite this being the first date proposed for this hearing, the Committee is
unwilling to consider changing the June 22, 2022 hearing date, despite the fact that the
aforementioned conflicts cannot be rescheduled. I was also told that the Committee would
not consider my offer to propose another knowledgeable witness from the Commanders
who could testify on that date, even if such witness, as a result of their day-to-day
responsibilities, would be in a far better position to answer questions about the workplace
culture of the team. The sole accommodation offered by the Committee was to permit Mr.
Snyder to appear virtually at the time the Committee has selected for the hearing without
regard to his schedule at that time. As I stated during the call, a virtual setting would hinder
my ability to appropriately advise my client during the hearing as I would not be physically
present with him.

The Committee’s insistence on holding a hearing while refusing to

accommodate my client’s reasonable requests is unfortunate in light of the stated goals of
the Committee’s investigation. As I explained in my earlier letter, any alleged workplace
misconduct under investigation by the Committee occurred more than a decade in the past.
Today, the Commanders are a model of how to make extraordinary improvements in
workplace culture. These improvements have resulted from the leadership and
commitment shown by Mr. and Mrs. Snyder in coordination with the NFL.1 Mrs. Snyder,
in particular, has been a trailblazer within the Commanders organization, serving as co-
CEO of the Team (one of just a few women who have ever served in that role in the history
of the NFL), representing the Team’s interests before the NFL, and becoming a leader in
the NFL’s diversity and inclusion efforts—all while helming the Snyders’ generous
charitable foundation and doing impactful work in breast cancer awareness.

The Commanders now have the most diverse and inclusive executive team
and football staff in the NFL. As I described in my June 6 letter, the Commanders’
leadership team includes the first Black president of an NFL franchise, one of just five
minority head coaches in the NFL, the first Black general manager in franchise history,
and the first full-time Black female coach in league history. In addition, Mr. and Mrs.
Snyder have substantially strengthened the Team’s anti-harassment policies and supported

1
NFL Commissioner Roger Goodell recognized and applauded the Snyders’ efforts to transform the
Team’s culture soon after the NFL conducted its review of the workplace misconduct allegations: “Over
the past 18 months, Dan and Tanya have recognized the need for change and have undertaken important
steps to make the workplace comfortable and dignified for all employees, and those changes, if sustained
and built upon, should allow the club to achieve its goal of having a truly first-tier workplace.” Press
Release, National Football League, NFL Announces Outcome of Washington Football Team Workplace
Review (July 1, 2021), https://nflcommunications.com/Pages/NFL-ANNOUNCES-OUTCOME-OF-
WASHINGTON-FOOTBALL-TEAM-WORKPLACE-REVIEW.aspx
 The Honorable Carolyn B. Maloney
The Honorable Raja Krishnamoorthi -4-

those policies through trainings and other resources focused on inclusivity and ethical
conduct. These enhancements have led Vestry Laight, an organization with substantial
expertise in workplace culture, to praise the Team’s ongoing “substantial transformation
of its culture, leadership and human resources practices.”

In sum, given the Committee’s refusal to accommodate my request to delay

the hearing and its unwillingness to recognize Mr. Snyder’s interests in a manner consistent
with fundamental fairness and due process, Mr. Snyder is unable to attend the hearing that
the Committee has scheduled for June 22, 2022. Mr. Snyder, together with Mrs. Snyder
and the Team, remain fully willing to cooperate with the Committee in all other respects,
including by continuing to discuss the reasonable requests regarding his potential
appearance, and by providing information to the Committee about the remarkable changes
undertaken by the Commanders to improve and enhance the experience of all
Commanders’ employees.

Sincerely,

/s/ Karen Patton Seymour

Karen Patton Seymour

cc: The Honorable James Comer, Ranking Member

Committee on Oversight and Reform

The Honorable Michael Cloud, Ranking Member

Subcommittee on Economic and Consumer Policy