Report to the Chicago Blackhawks Hockey Team Regarding

the Organization’s Response to Allegations of

Sexual Misconduct by a Former Coach

October 2021

Reid J. Schar
 Table of Contents
I. Executive Summary ........................................................................................................ 3

II. Our Investigation ............................................................................................................. 7

III. The Blackhawks Organization................................................................................. 14

IV. Brad Aldrich ................................................................................................................... 17

V. The 2010 National Hockey League Playoffs ...................................................... 20

VI. The Sexual Encounter Between John Doe and Brad Aldrich ....................... 23

VII. The Blackhawks’ Knowledge of What Occurred .............................................. 38

VIII. The Blackhawks’ Response During the 2010 Playoffs and Later .............. 55

IX. Events that Occurred After Aldrich’s Separation from the Blackhawks . 62

X. Conclusion ....................................................................................................................... 68

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 I. Executive Summarya

On May 7, 2021, a hockey player formerly affiliated with the Chicago

Blackhawks Hockey Team (the “Blackhawks”) filed a lawsuit against the team.
The player, John Doe, alleged that in May 2010, he was sexually assaulted by
the then-video coach for the Blackhawks. John Doe further alleged that the
Blackhawks were made aware of the alleged assault soon after it occurred and
failed to act to address the assault. In late June 2021, Jenner & Block LLP
(“Jenner & Block”) was hired by the Blackhawks to conduct an independent
investigation. Over the course of four months, we investigated (i) the conduct
of the former video coach, Brad Aldrich, in and around May 2010; (ii) the
extent to which individuals affiliated with the Blackhawks, including those in
senior management, knew about Aldrich’s conduct in May 2010, and when and
how those individuals learned about the conduct; and (iii) when and how
individuals affiliated with the Blackhawks, including those in senior
management, responded to the information they learned about Aldrich’s
conduct in May 2010.
Our investigation uncovered the following events. On May 8 or 9, 2010, John
Doe had a sexual encounter with Brad Aldrich. The Blackhawks were in the
midst of the National Hockey League (“NHL”) playoffs and ultimately won the
Stanley Cup for the first time since 1961. John Doe was a twenty-year-old
hockey player for the Blackhawks’ minor league affiliate team. He was called
up to Chicago during the 2010 playoffs to serve as a “Black Ace,” a prospect
player who could be available to play for the Blackhawks if needed. Brad
Aldrich was the Blackhawks’ twenty-seven-year-old video coach in his second
full year in the job. Aldrich was responsible for cutting video clips of game
footage for the other Blackhawks’ coaches.
Today, John Doe and Brad Aldrich have widely divergent recollections of the
sexual encounter, but both men agree an encounter occurred. The heart of the
difference between the two recollections is not only what occurred during the

a This report contains descriptions that are graphic in nature and language that

at times may be offensive.

Throughout this report, footnotes are denoted with letters and endnotes are
denoted with numbers.

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encounter, but most critically whether the encounter was consensual. John
Doe stated that the encounter was entirely non-consensual. John Doe stated,
among other details, that on one occasion, during the second week of May
2010, Aldrich invited him to his apartment, provided him with dinner and
drinks, told him he had the power to get John Doe onto the Blackhawks’ roster,
and turned on pornography. John Doe stated that Aldrich threatened John Doe
by telling John Doe he needed to act like he enjoyed the sexual encounter or
John Doe would never play in the NHL “or walk” again, forcibly performed oral
sex on John Doe, masturbated on John Doe’s back, and then threatened John
Doe again before John Doe was able to escape Aldrich’s apartment.
According to a confidant of John Doe who did not work for the Blackhawks, a
little over one week after the sexual encounter, John Doe shared certain details
of the encounter with the confidant. The confidant stated to us that John Doe
was clear at the time that the encounter was not consensual.
Brad Aldrich stated that the encounter was entirely consensual. Aldrich
stated, among other details, that he brought John Doe and a woman from a bar
to Aldrich’s apartment, played strip poker, and engaged in oral sex with the
woman, but not with John Doe. Aldrich further stated that after the woman
left Aldrich’s apartment, Aldrich and Doe watched pornography, Aldrich
received permission to engage in a sexual encounter with John Doe, Aldrich
performed oral sex on John Doe, and Aldrich received a “hand job” from John
Doe.
The woman present at the beginning of the encounter described by Aldrich
was located and interviewed as part of this investigation. The woman recalled
being present for and engaging in sexual activity with John Doe and Aldrich in
Aldrich’s apartment in Chicago, but leaving at a certain point while Aldrich and
John Doe remained at Aldrich’s apartment. Her version of events contradicts
certain of Aldrich’s statements, and also contradicts certain of John Doe’s
statements, who said that he went to Aldrich’s apartment building with the
woman on a different evening, but the woman left before entering the
apartment and no sexual encounter with the woman occurred.
On May 23, 2010, the Blackhawks’ Senior Director of Hockey Administration
Al MacIsaac was told by a Blackhawks employee that there may have been a
sexual encounter involving Aldrich and John Doe. MacIsaac dispatched the
Blackhawks’ mental skills coach and team counselor Jim Gary to speak to John

4
Doe to gather details of what may have happened. John Doe recalled that he
told Gary the details of the encounter with Aldrich as he reported them to us
during our investigation and as described above. Gary recalled a conversation
with John Doe on May 23, 2010 during which Gary obtained limited, yet still
very troubling information from John Doe that Gary believed to be true: that
Aldrich was pressuring John Doe to have sex with him and that Aldrich told
John Doe that if John Doe did not comply, Aldrich could harm John Doe’s
career.
Later on May 23, within an hour after the Blackhawks won the playoff game
that secured their place in the Stanley Cup Finals, five members of senior
management (then-President John McDonough, MacIsaac, General Manager
Stan Bowman, then-Executive Vice President Jay Blunk, and then-Assistant
General Manager Kevin Cheveldayoff), along with then-head coach Joel
Quenneville, and Gary, met to discuss what had been learned about Aldrich
and John Doe. Accounts of the meeting vary significantly, and the participants
had limited recollections of the details of the meeting. All of the participants
recalled being informed that there was an incident between Aldrich and John
Doe involving an unwelcome sexual advance, but, for the most part, the
participants reported that they only learned about the incident at a high
level—that Aldrich, a coach, tried to “get under the sheets” with John Doe, a
player. Gary recalled telling everyone in the meeting what he said John Doe
told him—that Aldrich was pressuring John Doe to have sex with him and that
Aldrich told John Doe that if John Doe did not submit to Aldrich’s advances, he
could harm John Doe’s career. None of the participants recalled being told
about the type of clearly non-consensual sexual conduct that is described by
John Doe in his lawsuit or was described during John Doe’s interview with us.
Bowman recalled that during the meeting, McDonough and Quenneville made
comments about the challenge of getting to the Stanley Cup Finals and a desire
to focus on the team and the playoffs. Several years later, MacIsaac, in
discussing the situation between Aldrich and John Doe with another
Blackhawks employee, stated that McDonough did not want any negative
publicity during the Stanley Cup Finals.
While there was a general failure to recall how the meeting ended, Bowman
recalled a statement by McDonough, the most senior member of management
in the room, that he would handle the situation. Regardless of who was, or was
perceived to be, responsible for handling the situation, Aldrich continued to

5
travel and work with the team, and participate in team activities throughout
the playoffs. We found no evidence that any action was taken to address the
issue until after the playoffs ended.
A Blackhawks policy at the time provided that all reports of sexual harassment
would be “promptly and thoroughly” investigated. Our investigation
uncovered no evidence, however, that McDonough or anyone else either
contacted Human Resources or initiated an investigation between May 23 and
June 14. The Blackhawks won the Stanley Cup on June 9. On June 10, during
an evening in which players, coaches, and other employees took the Stanley
Cup to various Chicago locations to celebrate the team’s championship, Aldrich
made a sexual advance on a Blackhawks intern who was twenty-two years old,
physically touching the intern. The intern rebuffed Aldrich’s advance and did
not report the encounter to management or Human Resources.
Four days later, on June 14, McDonough informed the Blackhawks’ then-
Director of Human Resources that Aldrich had allegedly made a sexual
advance on John Doe. According to the Director of Human Resources,
McDonough also informed her about the May 23 meeting in his office, during
which McDonough said it was decided that the group would not alert Human
Resources or do anything about the incident during the playoffs so as not to
disturb team chemistry. When interviewed, McDonough stated that he did not
recall this conversation with the Director of Human Resources.b
On June 16, 2010, the Director of Human Resources met with Aldrich and
offered him the option to undergo an investigation into what occurred with
John Doe or to resign. Aldrich chose to resign and signed a separation
agreement during the meeting. No investigation was conducted. Aldrich
received a severance and a playoff bonus, and continued to be paid a salary for
several months. He was permitted to host the Stanley Cup for a day in his
hometown, his name was engraved on the Stanley Cup, he received a

b Our investigation uncovered no evidence that the Blackhawks’ ownership

(including the current Chairman and the current CEO), or the current
President of Business Operations and the General Counsel (both of whom
joined the organization in 2021), were aware of the events of 2010 at any time
before John Doe’s potential civil lawsuit was brought to their attention ahead
of its actual filing.

6
championship ring, and he attended a Stanley Cup banner-raising ceremony at
the United Center. He went on to have paid and unpaid positions with USA
Hockey, the University of Notre Dame, Miami University in Ohio, and
Houghton High School in Houghton, Michigan. While in Houghton, in 2013,
Aldrich was arrested and pled guilty to fourth degree criminal sexual conduct
involving a minor.
This report is organized into ten sections, beginning with the scope and
execution of our investigation, and as follows:
 We describe the structure of, and relevant policies governing, the
Blackhawks organization in 2010, followed by background regarding
Brad Aldrich and his employment with the Blackhawks.

 For context, we provide a detailed recitation of the 2010 NHL playoffs,

when the majority of relevant events occurred; not all events in this
report, however, are listed in chronological order.

 We next provide a thorough account of the sexual encounter between

Aldrich and John Doe as told to us during our interviews of each
individual, and describe certain subsequent events.

 We describe in detail the Blackhawks’ knowledge of what occurred

between Aldrich and John Doe, including the conversations that
occurred between and among coaches, senior management, and John
Doe in the days and weeks that followed the encounter.

 We provide a detailed account of the Blackhawks’ actions and inactions

during and after the 2010 playoffs, Aldrich’s separation from the team,
and finally certain events in Aldrich’s life and John Doe’s life after the
playoffs.
At the end of this report, we offer our conclusions regarding the events that
transpired in 2010.
II. Our Investigation
Our investigation was precipitated by the filing of two complaints against the
Blackhawks in the Circuit Court of Cook County, Illinois, Law Division, in May
2021. On May 7, 2021, a lawsuit was filed in the Circuit Court of Cook County,

7
Illinois by “John Doe,” a former player in the Blackhawks organization, against
the Blackhawks.1 The lawsuit alleged two counts of negligence and one count
of violating the Illinois Human Rights Act, 775 ILCS 5/1-101 et seq., involving
alleged conduct in May 2010 by Brad Aldrich.2 John Doe filed an amended
complaint against the Blackhawks on July 22, 2021, providing additional
details about Aldrich’s alleged sexual misconduct and the Blackhawks’ alleged
negligence, and adding additional counts of willful and wanton misconduct
and intentional infliction of emotional distress.3
On May 26, 2021, a lawsuit was filed in the Circuit Court of Cook County by
“John Doe (2)” against the Blackhawks.4 This lawsuit alleged negligence and
willful and wanton conduct related to alleged actions or failure to act by the
Blackhawks after Aldrich left his employment with the Blackhawks in June
2010 and before Aldrich was arrested in Michigan in 2013.5 Plaintiff “John Doe
(2)” is described in his complaint as a former player on the Houghton High
School hockey team located in Houghton, Michigan.6 “John Doe (2)” filed an
amended complaint against the Blackhawks on July 22, 2021, adding new
allegations concerning the Blackhawks’ knowledge of sexual misconduct
allegations against Aldrich.7
A. Independence of Investigation

The Blackhawks directed us to follow the facts wherever they led and
permitted us to conduct an investigation independent of interference or
influence. We designed and executed the investigation with no limits from the
Blackhawks. In our sole discretion, we chose who to interview and what
materials to review. We were given prompt access to documents, employees,
and information, including contact information for current and former
employees and players.
The factual findings set forth in this report are solely advanced by Jenner &
Block. The Blackhawks exerted no influence over our reporting of the facts
and findings.
Our investigation is not a response by us or by the Blackhawks to John Doe’s
and John Doe (2)’s lawsuits. Jenner & Block is not serving as counsel for the
Blackhawks in the John Doe or John Doe (2) civil litigation.
Jenner & Block has never previously provided legal representation to the
Blackhawks. The Blackhawks paid Jenner & Block’s legal fees incurred during

8
the investigation, but payment was not contingent on any particular finding or
outcome.
B. Investigative Team

The investigative team was led by Partner Reid J. Schar, co-chair of Jenner &
Block’s Litigation Practice and a former federal prosecutor. The Jenner &
Block team that worked on the investigation has significant experience
conducting internal and government investigations, including investigations
involving allegations of sexual misconduct.
C. Scope of Investigation

We engaged in a broad and thorough investigation. As further described

below, we collected a large volume of electronic and hard copy documents and
records. We interviewed 139 witnesses, including current and former
Blackhawks’ personnel, from entry-level paid interns to the most senior
executives and coaching staff. Several witnesses were interviewed more than
once. We interviewed 21 current and former Blackhawks players and
Rockford IceHogs players. We interviewed John Doe, Brad Aldrich, and
individual players and personnel who were directly involved in the events
described below. We also interviewed several witnesses who never worked
for the Blackhawks but whose identities were raised during our investigation.
On August 2, 2021, the Blackhawks announced that a hotline number and
email address were available for anyone who believed that they had any
relevant information. The hotline was used and the information provided was
only accessible to Jenner & Block.
This report is not a record of every single fact, document, or witness statement
that we gathered, but instead focuses on key events and information.
1. Document Collection from the Blackhawks

We collected over 100 gigabytes of electronic records from over

145 individuals and 49 boxes of hard copy records. Of particular note, we
collected the following records:

 All available documents involving, concerning, relating to, or

referencing Brad Aldrich.

9
  All available documents involving, concerning, relating to, or
referencing John Doe.

 All available emails (unlimited by topic) for certain individuals

during the time period of May through September 2010.

 All available emails for certain individuals and for certain time
periods referencing USA Hockey, Notre Dame, Houghton, and Miami
University.

 Blackhawks and Rockford IceHogs Team Rosters.

 Travel records (including road trip itineraries, flight manifests, hotel

invoices, rooming assignments, expense reimbursement requests,
receipts, and per diem disbursements).

 Phone records for Blackhawks-issued cell phones and Blackhawks

desk phones.

 Records from Human Resources, including personnel files,

investigation files, employment and separation agreements, salary
information, performance evaluations, policies, and trainings.

 Payroll records, including salary, paycheck, and bonus records.

Our efforts to collect relevant records were met with several limitations often
present in investigations of matters over a decade old. First, while several
witnesses described relevant text messages to us, for the most part, those text
messages could not be collected because phones were no longer possessed,
paper records included only call logs and no text messages, and cellular
providers reported to us that they did not preserve text messages from 2010.
Second, in 2010, Blackhawks and IceHogs players did not have Blackhawks-
issued email addresses and there were therefore no Blackhawks emails for
2010 players. Third, although Blackhawks employees did have Blackhawks-
issued email addresses, until recently, it was the Blackhawks’ general practice
to not retain email data for individuals after their employment with the
Blackhawks ended. While we collected emails sent to and received by former
President John McDonough and Brad Aldrich from other individuals’ email
archives, McDonough’s and Aldrich’s original email archives were not retained

10
consistent with the Blackhawks’ general practice. We collected and reviewed
all emails with Aldrich that were retained by other individuals who are either
currently employed by the Blackhawks or whose emails were preserved for
other reasons. Fourth and finally, Brad Aldrich’s 2010 personnel file could not
be located after extensive searches.c We therefore could not review Aldrich’s
employment application and any notes that were added to Aldrich’s 2010 file
by Human Resources.
2. Efforts to Collect Records from External Sources

We collected records from several sources external to the Blackhawks,

including the entities for which Aldrich worked after he separated from the
Blackhawks. For example, we collected records from Miami University in
Ohio, which employed Aldrich in 2012. We contacted the University of Notre
Dame and requested relevant records; the University of Notre Dame declined
our request. We contacted Houghton High School and requested relevant
records; the school responded that it did not have any relevant records. We
contacted USA Hockey and received information orally. We also contacted the
National Hockey League Players’ Association (NHLPA) and made requests for
information and records. We received one document from the NHLPA and
assistance with arranging interviews with certain players.
We asked numerous witnesses about whether they possessed personal emails
and texts that could be relevant to our investigation. Several witnesses
voluntarily conducted searches for relevant records and provided text
messages and emails.
In addition, we contacted the apartment building in Chicago where Aldrich
lived in 2010 and requested visitor logs and camera footage. The building’s
current management informed us that 2010 visitor logs and camera footage
no longer exist.

c We located personnel files for other employees with similar hire and
departure dates as Aldrich, but there were other missing, non-pertinent
personnel files with similar hire and departure dates as Aldrich. We were
unable to determine the reason that any particular personnel file was or was
not maintained.

11
 3. Witnesses

We interviewed four categories of individuals:

 Current and former Blackhawks personnel, including individuals
within Business Operations (such as Sales, Marketing, Human
Resources, Finance, and Payroll personnel), and Hockey Operations
(coaches, including Aldrich,d training and equipment staff, and
management).

 Current and former Blackhawks players, including 14 of the

25 members of the 2009-2010 Blackhawks roster at the time of the
2010 playoffs.

 Current and former Rockford IceHogs players, including 5 of the

9 Black Aces in 2010, and including John Doe,e and two additional
IceHogs players.

 Individuals who never worked for the Blackhawks, but who otherwise
participated in or observed relevant events, or were confided in by John
Doe and others.

We began contacting witnesses on June 28, 2021. We interviewed

139 witnesses over the course of four months either in person, using the Zoom
application, or by telephone. Several witnesses were interviewed more than
once. Eleven individuals (none of whom were key witnesses) declined,
directly or through counsel, to be interviewed. Twenty-six individuals did not
respond to our requests for interviews.
4. Anonymity

In this report, we have anonymized the identity of most witnesses, including

but not limited to all individuals who affirmatively requested anonymity, as
well as many other witnesses. We have not anonymized the names of

d Aldrich’s counsel participated in our interview of Aldrich.

e John Doe’s counsel participated in our interview of John Doe. The
Blackhawks’ civil litigation counsel was also present.

12
individuals who provided statements to the media and in doing so, publicly
identified themselves as witnesses to certain events. We have also not
anonymized the names of senior management and the head coach, who were
directly involved in the handling of Aldrich’s conduct in 2010. To further
protect particular witnesses, we have generalized or omitted certain details
regarding particularly sensitive events, such as the location of the event, to
shield their identities.
Obtaining the cooperation of witnesses is critical in investigations such as this
one and important to uncovering the truth. We are grateful to the many
individuals who were willing to candidly speak to us about sensitive subjects.
Particularly given the sensitive nature of the events at issue and the
professional impact that may arise from cooperating with this investigation,
we ask that any reader of the report respect witness anonymity.
5. Witness Memory

Our investigation was affected by the limitations of witnesses’ memories.

Memory is malleable and subject to alteration over time, and it is not
surprising that witnesses would have divergent recollections of the same
events.8 During the course of our investigation, certain inaccurate information
has been publicly disseminated. Many witnesses reported that they were
exposed to news and social media posts regarding our investigation and
related topics. In our conversations with witnesses, we asked open-ended
questions so as not to lead a witness to a particular statement or fact, and we
clarified whether a witness remembered a particular fact with certainty and
due to first-hand knowledge, or remembered only after the information came
to the individual filtered through others or long after the event in question.
We also made robust efforts to independently corroborate certain memories
with records, such as contemporaneous emails, notes, travel records, and
phone records.
There are certain biases that further provide important context for witness
recollections. For example, confirmation bias is defined as the tendency to
search for or interpret information in a way that confirms one’s existing
beliefs.9 Hindsight bias is defined as the tendency to perceive past events as
being more predictable than they actually were.10 Investigations occurring
long after a disputed matter will be subject to such biases, and this
investigation was likely no exception. We also note that the allegations at the

13
heart of this investigation concern same-sex sexual interactions and
allegations of sexual misconduct in the context of professional men’s hockey
primarily in 2010. Several witnesses explicitly referenced the sensitivity
surrounding certain conduct at the time and in that context, and those
dynamics may have affected what people said and did then, and now. One
would also not expect every recitation of the events to every audience over
eleven years to be the same. During witness interviews, we made efforts to
explore the basis of a witness’s knowledge to test for potential biases and to
explore their awareness of their potential biases, including why they provided
more or less information in prior statements about certain events.
III. The Blackhawks Organization

This section describes the Blackhawks organization as it existed in 2010 and

the organization’s then-existing policies regarding sexual harassment, as well
as reporting, investigation, and discipline regarding sexual harassment
complaints.
In 2010, the Blackhawks organization was organized into two “Front Office”
components—Business Operations and Hockey Operations—both reporting
to the President of the organization, John McDonough.
A. Business Operations
Business Operations consisted of strategy, communications, corporate
partnerships, marketing, ticketing, and other business-related departments.
In 2010, Business Operations employed many people who were recent college
graduates and in their twenties, including paid interns and other entry-level
employees. In 2010, Jay Blunk oversaw Business Operations as a Senior Vice
President; he recently departed the organization.
B. Hockey Operations
Today and in 2010, Stan Bowman oversees Hockey Operations as the General
Manager (and today as President of Hockey Operations, as well).11 Bowman
oversees all day-to-day hockey operations, including drafting and trading
players, negotiating contracts, identifying prospect players, and overseeing
the hiring of coaches and hockey operations employees.12 In 2010, Al
MacIsaac served as the Senior Director of Hockey Administration and reported
directly to McDonough; today he is the Senior Vice President of Hockey

14
Operations.13 In 2010, Kevin Cheveldayoff was the Assistant General Manager;
he has since departed the organization.14
The coaching staff sits within Hockey Operations and, in 2010, consisted of
then-head coach Joel Quenneville, assistant coaches, and a mental skills coach,
James (“Jim”) Gary. Gary is a licensed clinical counselor and provided
performance-related coaching and personal counseling to players who sought
his assistance.15 Gary is now retired.16
C. Human Resources and Legal
In 2010, Human Resources was overseen by the Director of Human Resources,
an individual who recently departed the organization. The Director of Human
Resources reported directly to the President. In 2010, the organization did not
have an internal Legal Department or General Counsel. Today, the Blackhawks
have a General Counsel.
D. John McDonough
In 2010, John McDonough was the President of the Blackhawks and oversaw
the entire organization, including Business Operations, Hockey Operations,
and Human Resources.17 He reported to the Blackhawks’ ownership.18 As we
undertook our investigation, a number of witnesses expressed strong views of
McDonough’s management style and his control over decision-making within
the organization. Witnesses described McDonough as extremely controlling
and wanting to be—and being—the final decision-maker on numerous
occasions, including for some decisions that were perceived by witnesses as
not meriting McDonough’s involvement given McDonough’s role as President
of the organization.19 When interviewed, McDonough described his
leadership style as aggressive and direct, but denied that all decisions came to
him.20 McDonough stated that he generally let the Hockey Operations
employees make the “hockey decisions.”21 McDonough was released from the
Blackhawks in April 2020.
E. The Players
The players consisted of two groups of individuals. First was a roster of
individuals who were professional players in the NHL and under contract with
the Blackhawks. Second was a roster of individuals—also professional
players—who played for the Rockford IceHogs, which was in 2010 and
remains today an American Hockey League (AHL) “minor league” team that

15
was affiliated with and is now owned by the Blackhawks. During the NHL
playoffs, certain members of the IceHogs became “Black Aces”—prospect
players who were ready to play in the case of an injury, suspension, or any
other reason that a Blackhawks player was unable to play.
F. Relevant Policies
In 2010, the Front Office, the coaches, and the coaching staff were governed by
the Blackhawks’ Team Member Handbook.22 At the time, the Handbook had
last been updated in November 2005.23 The Handbook included a harassment
policy, which, among other provisions, prohibited harassing behavior and
required personnel to report harassing behavior by others.24 Sexual
harassment was defined to include unwelcome sexual advances and requests
for sexual favors when:
“[s]ubmission to or rejection of the conduct is an explicit or
implicit term or condition of employment …”
or
“[t]he conduct has the purpose or effect of unreasonably
interfering with an individual’s work performance or creates an
intimidating, hostile or offensive working environment.”25
Sexual harassment was also defined to include:
“[r]etaliation against an individual for complaining about
sexually harassing behavior.”26
The Handbook provided a procedure for reporting sexual harassment and
stated:
“[a]ll reports of sexual harassment will be promptly and
thoroughly investigated and appropriate action will be taken.
After the incident is investigated, you will be notified of the final
decision regarding your complaint.”27
The Handbook further stated that an employee
“found to have sexually harassed another individual will be
subject to disciplinary action, which could include immediate
termination from the Chicago Blackhawks. The penalty will be

16
 determined on a case-by-case basis, after careful review and
consideration of the specific incident(s).”28
Players received and were required to acknowledge a document titled “Team
Rules” at the beginning of the 2009-2010 season.29 The “Team Rules” were
based on standard rules provided and approved by the NHL and the NHLPA.30
The “Team Rules” for the 2009-2010 season did not address sexual
harassment, or reporting, investigation, or discipline for harassment.f
We asked dozens of the Blackhawks’ current and former personnel, including
coaches affiliated with the organization in 2010, about their knowledge of the
Blackhawks’ sexual harassment policy and procedures in 2010. Most of these
witnesses, including some in senior management, were unaware of the
relevant policy or procedures in 2010 related to sexual harassment, though
some were required to acknowledge receipt of the Handbook in 2010 or
earlier.31
IV. Brad Aldrich

In this section, we provide an account of the hiring and employment of Brad

Aldrich as the video coach for the Blackhawks from July 2008 through June
2010. The video coach was responsible for breaking down pre-game video,
cutting game clips for the coaches to use with the players, running video
sessions on a computer while the coaches ran their sessions for the players,
and cutting clips of individual players as requested by the players and
coaches.32
During the summer of 2008, the video coach for the Blackhawks transitioned
to a scouting role for the team, leaving the position vacant.33 At the time,
Aldrich was the Coordinator of Hockey Operations/Video Coordinator for the
University of Notre Dame Hockey Team.34 The General Manager for the
Blackhawks at the time, Dale Tallon, received a message from an individual
affiliated with the San Jose Sharks, another NHL team, recommending that
Tallon look out for Aldrich’s resume.35 Tallon recalled that after receiving the

fThe “Team Rules” covered a variety of topics, including alcohol consumption

and use of tobacco products, gambling, attendance at practices and games,
dress code, reporting of injuries and illnesses, interacting with the media and
fans, game penalties, use of illegal equipment, and discipline and fines.

17
message from the Sharks, he received Aldrich’s resume.36 Other witnesses
recalled that Tallon was friends with the General Manager of the Sharks and
that Aldrich’s father was the Sharks’ equipment manager.37 The then-Director
of Human Resources recalled that Tallon arranged Aldrich’s interview for the
video coach position.38
For his part, Aldrich recalled that he received a phone call from Stan Bowman,
who was the Assistant General Manager of the Blackhawks at the time.39
Aldrich recalled Bowman describing a video coach position and inviting
Aldrich to interview for the position.40 When interviewed, Bowman said he
did not recall being involved in Aldrich’s interview or hiring process.41
Bowman also said such involvement by him was unlikely, given that Bowman
was not involved in the hiring of coaches or assistant coaches at the time.42
Bowman said that he did not know how Aldrich became an employee of the
Blackhawks.43
Regardless of how Aldrich came to the Blackhawks’ attention and who
arranged for his interview, Aldrich came to Chicago to interview for the video
coach position.44 Aldrich recalled being interviewed by Tallon in his office, and
meeting Bowman and McDonough, both of whom Aldrich said stopped by
Tallon’s office.45 The Director of Human Resources also recalled interviewing
Aldrich.46 When interviewed, Aldrich stated that he believed the Blackhawks
contacted the University of Notre Dame for a reference, but there were no
witnesses in our investigation who recalled contacting the University of Notre
Dame.47 We requested records regarding Aldrich from the University of Notre
Dame; the University of Notre Dame declined our request. Aldrich recalled
that he was offered the video coach position on the same day as his
interview.48
Aldrich was employed as the video coach for the Blackhawks from August 1,
2008, until June 16, 2010.49 He reported directly to the head coach, who was
initially Denis Savard and later Joel Quenneville.50 Aldrich and some players
and coaches recalled that players could request their individual video clips
from Aldrich.51 Aldrich gave the requested clips to the coaches, who would in
turn show the clips to the players.52 During the games, Aldrich worked from
the locker room, listening to updates from coaches and cutting videos for the
coaches to show the players, sometimes between periods.53

18
During his employment with the Blackhawks, Aldrich appears to have
received three formal performance evaluations, each providing positive
feedback. The three evaluations we located were unsigned Microsoft Word
documents stored in electronic folders; because we were unable to locate
Aldrich’s personnel file, we cannot say with certainty that the evaluations we
located were the final versions or were in fact ever finalized, though no one to
whom we showed the unsigned evaluations suggested they were materially
different from final versions. In a January 2009 unsigned performance
evaluation, Tallon wrote that Aldrich “has enhanced the job of Video Coach [to]
provid[e] more information than previous individuals in that role” and that
the other coaches had “all very positive” feedback regarding Aldrich.54 Tallon
also wrote: “[i]f there was an area where [Aldrich] had some adjusting to do[,]
it was in his personality” and Aldrich “has very high confidence in his ability
to the point where it borders on arrogance.”55
In a June 2009 unsigned performance evaluation, Quenneville wrote that
“Brad did a great job to accommodate the coaches preparing for meetings and
their everyday needs … I believe going forward Brad can be more efficient by
being in a separate working environment [and] not in the middle constantly
being disturbed.”56 In his last performance evaluation, dated June 29, 2010
(after Aldrich had separated from the team), but unsigned by Quenneville and
Aldrich, Quenneville wrote: “Aldrich did a great job for the Coaching staff in
preparing us for all of our meetings and coordinating several tasks that we
forward his way. Brad has several people relying on him at the same moment
and has a way of deflecting and accommodating everyone at once … Congrats
on winning the Stanley Cup!”57 When interviewed, Quenneville stated that he
did not recall whether he wrote the June 29, 2010 evaluation of Aldrich, or if
he knew whether Aldrich had been separated at the time, but did not dispute
that he may have written the evaluation.58 He further stated that the review
looked to him like something he would write.59 Additional performance
evaluations of coaches dated June 29, 2010, also unsigned by Quenneville,
were similarly written and contain the same language congratulating the
employee on the Stanley Cup win.
Witnesses had varying opinions of Aldrich, although it is unclear how
witnesses’ current views of Aldrich have been colored by the allegations made
since Aldrich departed the Blackhawks in 2010. Several Front Office
personnel who knew Aldrich in 2010 described him as friendly,60 outgoing,61

19
and nice.62 Several former players and coaches viewed Aldrich’s work
performance positively.63 Witnesses noted that Aldrich got along well with the
coaches and was “chummy” with many individuals on the Blackhawks’ staff.64
Several former players explained that they enjoyed speaking to Aldrich
because Aldrich informed players in advance if they had a chance to make the
game lineup.65
Other witnesses had very different views of Aldrich. One former player
described Aldrich as intense and “cocky.”66 Some witnesses described Aldrich
as “creepy,”67 someone who kept to himself,68 peculiar,69 standoffish, and
arrogant.70 Several witnesses recalled Aldrich making inappropriate
comments, including jokes with sexual content, bragging or speaking
inappropriately about sexual interactions with women, and speaking
frequently about how he dated many different women.71 Some witnesses
observed Aldrich “hitting on” female Front Office employees.72 One former
player—who regularly socialized with Aldrich during the 2009-2010 season—
believed at the time that Aldrich spoke about dating many women because he
was attempting to mask his sexual orientation.73
On the eve of the 2010 NHL playoffs, Aldrich had served in the video coach
position for two seasons.
V. The 2010 National Hockey League Playoffs

Many of the events at issue in our investigation occurred during the 2010 NHL
playoffs. On April 4, 2010, the Blackhawks won the Central Division title, and
on April 11, 2010, entered the playoffs as the second overall seed in the
Western Conference.74 The Western Conference Quarterfinals, in which the
Blackhawks played the Nashville Predators, started on April 16 and ended on
April 26, with the Blackhawks winning the series.75 On April 24, 2010, just
before the conclusion of the Nashville series, the Blackhawks assigned nine
prospect players from the Rockford IceHogs, including John Doe, to serve as
Black Aces during the remainder of the 2010 playoffs.76 The Blackhawks went
on to win the Western Conference Semifinals against the Vancouver Canucks
(May 11, 2010), and the Western Conference Finals against the San Jose Sharks
(May 23, 2010).77 The Blackhawks won the Stanley Cup Finals against the
Philadelphia Flyers on June 9, 2010.78 Because it is relevant to the sequence,
context, and timing of events as further discussed in this report, the schedule
of games, locations, and certain off days and flights was as follows:

20
21
 A. The Black Aces

During the playoffs, there were two distinct groups of players affiliated with
the Blackhawks: players on the Blackhawks’ NHL roster and the Black Aces.
The Black Aces were prospect players who were ready to play in the NHL
playoffs in the case of an injury, suspension, or any other reason that a
Blackhawks player was unable to play during the playoffs.79 A Black Ace
would play only if the Blackhawks had already depleted available back-up
players on the NHL roster, a very unlikely eventuality.80 The Black Aces were
expected to watch games, practice with the other Black Aces, and travel with
the Blackhawks so that they could experience the playoffs on the theory that
such experiences might be relevant later in their Blackhawks careers.81 The
Black Aces practiced at a separate rink from the Blackhawks and were
typically not coached or trained by the Blackhawks’ training and coaching
staff.82 Members of the Rockford IceHogs’ coaching and training staff traveled
to Chicago to support the Black Aces.83 The Rockford staff, however, did not
travel with the Black Aces to away games.84 Several witnesses, including two
Black Aces, recalled having a significant amount of down time because their
chances of playing were slim and their practice sessions were limited.85
B. Aldrich’s Interactions with the Black Aces

On several occasions during the 2010 playoffs, Aldrich socialized with one or
more of the Black Aces. Two former Black Aces and Aldrich himself recalled
Aldrich joining several of the Black Aces when they went to bars and
restaurants in Chicago and on the road.86 Several witnesses recalled observing
Aldrich with the Black Aces.87 Some former Black Aces recalled Aldrich
hosting several Black Aces at the pool at his apartment building,88 hosting
Black Aces inside his apartment,89 and gathering as a group for massages at
the team hotel on the road.90 Phone records corroborate that Aldrich and
multiple Black Aces were in frequent contact with each other in May and June
of 2010.91
Several Black Aces perceived Aldrich to have access to coaches and
information the Black Aces valued. During his interview, John Doe recalled
coaches encouraging him and the other Black Aces to request video clips from
Aldrich and use Aldrich as a resource.92 Another Black Ace and a member of
the 2010 Blackhawks team both recalled that Aldrich provided them with
advance notice and intelligence on the Blackhawks’ lineup for game days.93

22
One member of the 2010 Blackhawks team recalled that many players relied
on Aldrich to tell them what coaches were thinking.94 This player further
recalled that Aldrich texted the player after games to share what was being
discussed in the coaches’ room and what Quenneville thought of the player’s
performance.95
One particular Black Ace, who we refer to throughout this report as Black
Ace 1, stated during his interview that he and other Black Aces were aware
that Aldrich participated in the meetings held by the other Blackhawks
coaches.96 Black Ace 1 also stated that he and other Black Aces socialized with
Aldrich during the 2010 playoffs because they wanted to know how to succeed
in the NHL.97 Black Ace 1 recalled Aldrich stating that he “could bury us” in
the Blackhawks organization and make sure “you could never play” by saying
“not nice things about us.”98 Six additional witnesses told us that, after
Aldrich’s separation from the Blackhawks, each heard a rumor that Aldrich
threatened players’ careers.99
***
It was against this backdrop—the Blackhawks’ success during the 2010
playoffs and the Black Aces arriving in Chicago and having significant down
time during which they socialized with Brad Aldrich—that John Doe had a
sexual encounter with Brad Aldrich.
VI. The Sexual Encounter Between John Doe and Brad Aldrich

In the following pages, we describe an encounter between John Doe and

Aldrich, first as told to us by John Doe, and then as told to us by Aldrich. It is
undisputed that a sexual encounter occurred involving John Doe and Aldrich
and that it occurred on May 8 or May 9, 2010.g The account by Aldrich diverges
from the account by John Doe in numerous respects, including whether the
encounter was consensual. We also include below an account from a woman
who described an evening during which she went to Aldrich’s apartment with
Aldrich and John Doe. Aldrich and John Doe have differing accounts of their
interaction with the woman. We describe accounts from secondary witnesses,

g Despite efforts to confirm certain facts, the precise date of the sexual
encounter remains unclear, although the facts as detailed below strongly
suggest the encounter occurred on May 8 or 9, 2010.

23
including a confidant of John Doe who did not work for the Blackhawks and
who spoke to John Doe soon after the encounter with Aldrich. Below we set
forth all of the relevant details as reported to us by John Doe, Brad Aldrich, and
the other witnesses.
A. John Doe

From May 4 until May 8, 2010, the Blackhawks and the Black Aces were in
Vancouver for Games 3 and 4 of the Western Conference Semifinals.100

John Doe recalled that he socialized with Aldrich and other Black Aces while
the team was in Vancouver.101 John Doe also recalled Aldrich inviting him to
Aldrich’s hotel room in Vancouver.102 John Doe stated that Aldrich suggested
they could watch hockey in the hotel room and that it would make John Doe a
better player.103 John Doe stated that he declined the invitation.104 Also while
in Vancouver, John Doe met with a confidant—who did not work for the
Blackhawks—for dinner, which occurred sometime between May 4 and May
7.105 When interviewed, the confidant recalled that during the meal, John Doe
said nothing out of the ordinary or in particular regarding Aldrich, suggesting
to the confidant (who soon thereafter learned about the sexual encounter
between John Doe and Aldrich) that the encounter had not occurred before the
Vancouver dinner.106
1. May 8 to 9, 2010
On May 8, the Blackhawks traveled back to Chicago and, on May 9, the
Blackhawks played Game 5 against Vancouver.107 John Doe recalled that after
Game 5 on May 9, he was with a group at a bar in Chicago.108 John Doe recalled
that Aldrich was present and introduced John Doe to a woman.109 John Doe

24
next recalled going to Aldrich’s apartment building with Aldrich and the
woman. Before they entered Aldrich’s apartment, John Doe recalled, the
woman left.110 John Doe recalled following the woman to ask why she was
leaving.111 John Doe recalled that Aldrich appeared to John Doe to be unhappy
that John Doe followed the woman instead of entering his apartment.112
During his interview, John Doe did not describe any additional interactions
with Aldrich on this evening, and did not describe any evening during which
John Doe, Aldrich, and the woman were present and engaged in sexual
activity.113
John Doe recalled that the Blackhawks traveled to Vancouver on May 10 for
Game 6, which took place on May 11, and that he and other Black Aces stayed
in Chicago.114 Travel records confirm that the team, including Aldrich,
traveled on May 10 to Vancouver for Game 6.115 John Doe recalled receiving
text messages from Aldrich while Aldrich was in Vancouver. h, 116

John Doe also recalled that Aldrich frequently referenced that around this
time, Aldrich was speaking to Quenneville about John Doe, and Quenneville
wanted Aldrich to show John Doe videos or talk to John Doe about hockey.117
John Doe recalled that Aldrich made clear that Aldrich had a direct line to
Quenneville.118

On May 12, the day after the Blackhawks’ Game 6 series-clinching victory
against Vancouver, the Blackhawks traveled from Vancouver directly to San
Jose for several off days before starting the Western Conference Finals against
the San Jose Sharks.119 Travel records and dozens of witness interviews reflect
that Aldrich traveled directly from Vancouver to San Jose and did not return
to Chicago until May 19.120 Thus, records and multiple eyewitnesses place
Aldrich in either Vancouver or San Jose for the entire period of May 10 to May

hAs noted in Section II.C., text messages between John Doe and Aldrich could
not be collected because John Doe and Aldrich stated that they no longer
possess the phones they used in 2010. The cellular provider for Aldrich’s
Blackhawks-issued cell phone reported to us that it did not preserve text
messages from 2010.

25
19. John Doe traveled from Chicago to San Jose on a commercial flight on May
12 and stayed in San Jose until May 19.121

John Doe stated that while he is “blurry” on the exact date of the sexual
encounter involving Aldrich, he believed that the encounter occurred in
Chicago at some point after May 9, the evening during which John Doe stated
the woman did not enter Aldrich’s apartment.122 On this point, it appears John
Doe’s recollection was initially inaccurate. As noted above, records and
multiple other witnesses place Aldrich outside of Chicago between May 10 and
May 19 and John Doe himself away from Chicago between May 12 and May 19.
A photograph of the team in San Jose on May 14 appears to include both
Aldrich and John Doe. However, in a later communication provided to us on
the topic, John Doe indicated he believed the sexual encounter with Aldrich
occurred after Games 3 and 4 (May 5 and 7) of the Vancouver series, on an off
day in Chicago, and before travel to San Jose.123 Based on John Doe’s later
communication, it appears what John Doe describes as the sexual encounter,
as further detailed below, occurred on May 8 or May 9.
2. The Encounter
Regardless of the exact date of the sexual encounter, John Doe recalled that the
evening of the incident with Aldrich started when John Doe received a text

26
message from Aldrich inviting John Doe to Aldrich’s apartment in Chicago.124
John Doe recalled that Aldrich wrote in the text message that Aldrich could
provide a home-cooked meal and talk with John Doe about hockey.125 As
context, John Doe stated during his interview that he believed that Aldrich was
being nice to John Doe because John Doe had been staying in a hotel for a long
time.126
John Doe recalled that when he received the text message, he was hungover
from the previous evening’s activities.127 He recalled that none of the other
Black Aces wanted to go to dinner with him at a restaurant, which led John Doe
to accept Aldrich’s invitation for dinner at Aldrich’s apartment.128
John Doe recalled entering Aldrich’s apartment, where a small TV or computer
was showing a horse race. John Doe stated that Aldrich offered and made John
Doe a mixed alcoholic drink.129 John Doe stated that Aldrich was making
dinner and continued to cook and talk about horse races and hockey skills.130
John Doe stated that Aldrich told John Doe what he needed to do to be
successful as a player.131 John Doe recalled that Aldrich said Quenneville
listened to Aldrich and if Aldrich told Quenneville that John Doe was working
hard, Aldrich could get John Doe on the Blackhawks’ roster.132 John Doe
recalled that Aldrich cooked a seafood pasta dish and continued to make small
talk.133 John Doe recalled that he was looking forward to the dish because he
had not had a home-cooked meal in a long time.134
John Doe further recalled that he drank two or three alcoholic drinks during
dinner.135 After dinner, John Doe stated, he declined another drink and Aldrich
suggested watching hockey.136 John Doe recalled that he and Aldrich moved
to the futon in Aldrich’s living room area. John Doe recalled that the futon was
reclined about 75 percent, and Aldrich gave John Doe two pillows and used
two pillows for himself.137 John Doe recalled that Aldrich then reclined the
futon completely and told John Doe it would be more comfortable.138 John Doe
stated that after the hockey program ended or a commercial started, Aldrich
took the remote and turned on pornography.139 John Doe stated that Aldrich
then turned back to the hockey program and said, “whoops, guess you know
what I was watching last night.”140 John Doe stated that Aldrich then turned
on pornography a second time, and this time left the pornography on the
television for about 15 to 20 seconds before flipping back to the hockey
program.141 John Doe stated that Aldrich said that there must be something
wrong with the remote control.142 John Doe stated that Aldrich then turned

27
on pornography a third time and left the pornography playing on the
television.143 During our interview, John Doe became emotional and choked
up as he described the following events.144
John Doe stated that Aldrich then began to touch himself and asked John Doe
if John Doe was going to touch himself.145 John Doe recalled that he said “no”
to Aldrich, and then Aldrich told John Doe to touch himself. John Doe recalled
that he told Aldrich that he was uncomfortable.146 John Doe stated that he then
put his hand into his pants for approximately ten seconds.147 John Doe recalled
asking Aldrich, “happy?” John Doe recalled that Aldrich responded that he was
not happy and rolled over on the futon towards John Doe, started to rub John
Doe’s leg, and tried to start kissing John Doe.148 John Doe recalled that Aldrich
was on John Doe’s right side and that John Doe pushed Aldrich with his left
hand as he punched Aldrich on or near Aldrich’s eye with his right hand.149
John Doe recalled that after he punched Aldrich, Aldrich stood up, grabbed a
souvenir Cubs miniature baseball bat that was on either a shelf or window,
and told John Doe that John Doe was not going anywhere.150 John Doe recalled
that he was sitting up at this point and froze.151 John Doe recalled that Aldrich
said words to the effect of, “If you don’t lay down and act like you enjoy it, I’ll
make sure you never play in the NHL or walk again.”152 John Doe recalled that
he scooted himself as far away as he could from Aldrich. John Doe recalled that
Aldrich got on top of him, started to forcefully kiss him, and shoved his tongue
into John Doe’s mouth.153 John Doe recalled that, after approximately thirty
seconds, John Doe began to gag and told Aldrich that his tongue was “too
fat.”154 John Doe recalled that in response, Aldrich said words to the effect of,
“maybe you’ll like this with my fat tongue” and then began to perform oral sex
on John Doe.155
John Doe recalled that Aldrich continued to perform oral sex on John Doe,
stopping only to tell John Doe to act like he was enjoying it.156 John Doe
recalled that Aldrich stopped performing oral sex on John Doe once John Doe
ejaculated in Aldrich’s mouth.157 John Doe recalled that Aldrich then told John
Doe that John Doe must have liked it, which Aldrich said meant to Aldrich that
John Doe was gay.158 John Doe recalled that Aldrich then sat up, paused, and
told John Doe to roll over onto his stomach.159 John Doe recalled that he said
“no,” and Aldrich again told John Doe to roll over.160 John Doe recalled that he
rolled over and Aldrich got on top of John Doe.161 John Doe recalled that
Aldrich then said words to the effect of “don’t worry, I won’t put it in you.”

28
John Doe recalled that Aldrich “dry humped” John Doe until Aldrich ejaculated
on John Doe’s back.162 John Doe recalled that Aldrich then wiped off John Doe’s
back, stating words to the effect of: “You can’t tell anyone about this; it is our
little secret; no one can find out or I will make sure you never play in the
NHL.”163
John Doe next recalled that Aldrich went into the bedroom or bathroom.164
John Doe stated that he quickly put on his clothes, ran out of the apartment,
and ran down the stairs as fast as he could.165 John Doe stated that he took a
taxi back to his hotel and locked himself in his room. John Doe recalled that he
was terrified and shaking.166 John Doe also recalled receiving text messages
from Aldrich asking where John Doe went and telling John Doe that John Doe
could not tell anyone what happened.167
John Doe stated that over the course of the next two weeks, he received many
text messages from Aldrich.168 John Doe also recalled that before Games 1 and
2 of the San Jose series, when the Blackhawks and the Black Aces were in San
Jose, Aldrich came to one or two of the Black Aces’ practices.169 John Doe
recalled feeling scared and sick when he saw Aldrich and stated that he
believed Aldrich had the power to dictate John Doe’s career.170
B. John Doe’s Confidant

An individual who we will refer to as John Doe’s confidant recalled receiving a

phone call from John Doe on May 17, 2010.171 On that date, the Blackhawks
and the Black Aces were in San Jose, and it was an off day between Game 1 and
Game 2 against the San Jose Sharks.172 The confidant was certain of the date
of the call because he received the call on the day of the confidant’s wedding
anniversary (a point we confirmed by receiving from the confidant a
photograph of his wedding invitation).173 When interviewed, the confidant
stated that John Doe could barely speak and was crying throughout the May
17 phone call.174 The confidant stated that he initially wondered to himself
whether John Doe had been in a car accident and asked John Doe to catch his
breath.175 The confidant recalled John Doe stating that he had something
difficult to tell him and then describing a sexual encounter involving
Aldrich.176
The confidant recalled John Doe telling him that Aldrich, John Doe, and a
handful of teammates were recently out together in Chicago.177 The confidant
recalled John Doe explaining that Aldrich and John Doe separated from the

29
group with a woman, and the three individuals went to Aldrich’s apartment.178
The confidant recalled John Doe stating that he had sexual relations with the
woman while Aldrich watched from a corner where he was masturbating.179
The woman then left Aldrich’s apartment.180
The confidant further recalled John Doe describing a second interaction with
Aldrich during the May 17, 2010 call, although in a second interview the
confidant stated that he was uncertain whether it was a separate evening John
Doe was describing or a continuation of the events that occurred after the
woman left Aldrich’s apartment.181 The confidant recalled John Doe saying
that he and Aldrich watched hockey highlights together and Aldrich
repeatedly flipped the video to pornography before saying “whoops” and
flipping the video back to hockey highlights.182 The confidant recalled John
Doe telling him that John Doe had two or three alcoholic drinks and did not
feel well.183 John Doe told the confidant that he next relaxed on a futon in
Aldrich’s apartment and fell asleep.184 John Doe said to the confidant that
when he woke up, Aldrich was on top of him and trying to or directly
performing oral sex on John Doe.185 The confidant recalled John Doe saying
that he tried to push Aldrich back and Aldrich grabbed a Chicago Cubs
souvenir bat or souvenir hockey stick and threatened to hit John Doe with the
bat or stick, or did hit him with the bat or stick.186 The confidant recalled that
John Doe said he could not “come to” and explained to the confidant that he
felt that he was under the influence to a greater extent than the alcohol he had
consumed.187 The confidant recalled that John Doe said Aldrich continued to
perform oral sex on John Doe, masturbated, and ejaculated on John Doe.188
John Doe told the confidant that he felt threatened by Aldrich, disgusted, and
that he wanted to leave.189 According to the confidant, Aldrich informed John
Doe that if he told anyone, he was “done” and would never play an NHL
game.190 When interviewed, the confidant did not recall whether John Doe
stayed at Aldrich’s apartment after the encounter.191
The confidant further recalled that John Doe stated he did not know why he
felt he could not get off the futon in Aldrich’s apartment, but he felt that he did
not have the physical strength to do so.192 The confidant recalled asking John
Doe to further explain how he could not fight off Aldrich, and reminded John
Doe that he “fights for a living.”193 The confidant recalled that John Doe
responded that he was in and out of consciousness and mentioned to the
confidant the possibility of having been drugged.194

30
The confidant also recalled telling John Doe that John Doe’s parents should
know about the incident.195 The confidant recalled John Doe stating that he
did not want anyone to know, including his parents.196 The confidant recalled
asking John Doe for permission to speak to the Blackhawks, which John Doe
granted.197 This point is further addressed below.198
C. Brad Aldrich
Aldrich provided a different version of the encounter with John Doe, including
his view that the encounter was consensual.

Aldrich stated that, at some point early in the 2010 playoffs, he confided to
John Doe and Black Ace 1 that he was gay.199 Aldrich recalled that, after this
conversation, he felt that Black Ace 1 was supportive of Aldrich but he
regretted telling John Doe.200 Aldrich stated that he felt threatened by John
Doe and worried that John Doe was going to reveal his sexual orientation to
others.201 Aldrich further stated that he felt that John Doe asked questions that
made him feel uncomfortable.202 Despite stating that he felt concerned that
John Doe would reveal his sexual orientation, Aldrich also stated that leading
up to the night of the sexual encounter with John Doe, Aldrich experienced
what he believed to be flirtatious interactions between him and John Doe.203
Aldrich stated that none of the interactions before the night of the encounter
were physical.204 John Doe did not recall a conversation with Aldrich about
Aldrich’s sexual orientation; Black Ace 1 recalled the conversation but
provided no details regarding who else, if anyone, was present for the
conversation.205
On the evening of the encounter, which Aldrich recalled was either May 8 or
May 9, 2010, Aldrich said that he and John Doe were socializing and drinking
at a bar in Chicago with a woman.206 Aldrich stated that in general, during the
2009-2010 season, he engaged in excessive drinking. Aldrich recalled that late
in the evening, he, John Doe, and the woman left the bar and traveled together
to Aldrich’s apartment.207 Aldrich recalled that he, John Doe, and the woman
played strip poker in Aldrich’s apartment.208 Aldrich recalled that the game
ended with none of the three individuals wearing clothes.209 Aldrich recalled
that the three individuals started kissing and engaging in oral sex.210 Aldrich
recalled that all three individuals participated in the oral sex, although the
woman, as further described below, said that Aldrich and John Doe did not
perform oral sex on each other in the woman’s presence.211 Aldrich asserted

31
that in his view, the night was fun and playful.212 Aldrich recalled that at some
point during this interaction, the woman left Aldrich’s apartment after he
believed she started to menstruate.213 Aldrich recalled that after the woman
left the apartment, John Doe did not put on his clothes. Aldrich stated that John
Doe played pornography on his phone.214 Aldrich recalled that he and John
Doe sat on the futon in Aldrich’s apartment and both individuals began to
masturbate while the pornography played.215 Aldrich recalled that he turned
to John Doe and asked John Doe if “it [was] time to take this to the next step.”216
Aldrich stated that he vividly remembered John Doe’s response.217 Aldrich
stated that John Doe said, “I’ve always wanted to try it.”218 Aldrich stated that
he performed oral sex on John Doe and John Doe gave Aldrich a “hand job.”219
Aldrich stated that John Doe stayed the night and slept in Aldrich’s
apartment.220 Aldrich stated that in his view, he never had the sense that John
Doe wanted to stop the encounter and did not tell Aldrich to stop.221 Aldrich
stated that John Doe was not unconscious when the sexual encounter occurred
and that there were no drugs involved.222
Aldrich stated that he did not recall his interactions the next morning with
John Doe or John Doe leaving in the morning.223 Aldrich stated that he was not
concerned at the time about the player-coach dynamic, nor did he feel that he
did anything wrong.224 Aldrich stated that he never spoke to anyone about the
sexual encounter with John Doe.225 Aldrich also stated that he foresaw a sexual
encounter with John Doe because of the flirtatious interactions he said he had
with John Doe leading up to the sexual encounter.226 Aldrich denied sexually
assaulting John Doe.227 Aldrich also denied threatening John Doe, flipping
between pornography and sports in the presence of John Doe, and cautioning
John Doe against telling anyone about the encounter.228
D. The Woman

The woman who came to Aldrich’s apartment was located and interviewed.
She provided an account that corroborated certain aspects of John Doe’s and
Aldrich’s accounts, and differed in certain respects as well.
The woman recalled that she first met Aldrich at a bar in Chicago where he and
certain hockey players socialized.229 The woman stated that she and Aldrich
texted occasionally and she initially believed Aldrich to be nice.230 The woman
recalled only one occasion when she and Aldrich socialized with each other
outside of the bar.231 The woman recalled that, on this night, she was drinking

32
with Aldrich and an individual whom she believed to be John Doe at a bar in
Chicago.232 The woman stated that she, Aldrich, and John Doe may have
traveled to a second location, but she did not recall with certainty. 233 The next
event the woman recalled was Aldrich asking her: “Why don’t you come back
to my condo?”234
The woman stated that she accepted Aldrich’s invitation.235 The woman stated
that she went to Aldrich’s residence with Aldrich and John Doe and they
watched ESPN.236 The woman recalled that someone, whom she believed to
be Aldrich, asked if she wanted to watch pornography, which she declined.237
The woman stated that she, Aldrich, and John Doe then played strip poker, and
John Doe and Aldrich engaged in oral sex with her.238 The woman stated that
she did not believe that Aldrich and John Doe engaged in oral sex with each
other, kissed each other, or touched each other’s genitals.239 The woman
stated she did not see either Aldrich or John Doe ejaculate or masturbate.240
The woman recalled that Aldrich wanted to record a video during the
interaction and the woman declined.241 The woman recalled that John Doe
was nice to her during the interaction.242
The woman stated that at some point during the interaction, Aldrich scratched
her and she started to bleed.243 The woman stated that when Aldrich
scratched her, she realized she did not want to be at Aldrich’s residence and
decided to leave.244 The woman recalled that Aldrich was aggressive and told
her that she should stay the night at his residence and in his bed.245 The
woman stated that, after turning down Aldrich’s requests for her to sleep in
his bedroom, she waited in the building lobby for 45 minutes for a taxi.246 The
woman stated that she did not see John Doe or Aldrich in the lobby while she
waited for a taxi.247 The woman described Aldrich as the instigator of events
that occurred in her presence that evening.248 When interviewed, the woman
stated nothing about John Doe following her after she did not enter Aldrich’s
apartment and she made clear she did enter Aldrich’s apartment and had a
sexual encounter with Aldrich and John Doe.249
The woman never spoke to John Doe again.250 She recalled seeing Aldrich
again in Chicago once and he told her that he had left the Blackhawks.251

33
 E. Interactions between John Doe and Aldrich after the Sexual
Encounter

John Doe recalled that, after the sexual encounter with Aldrich, while the team
was in San Jose from May 12 through May 19, John Doe went out to a bar with
a group of ten people, including Aldrich.252 John Doe recalled that Aldrich was
constantly texting John Doe and begging John Doe to come to Aldrich’s hotel
room.253 John Doe recalled that, on the way back to the team hotel, the group
stopped at Subway or Pita Pit.254 John Doe recalled that Aldrich stood behind
John Doe in the line and pinched and poked John Doe.255 John Doe also recalled
seeing over the shoulder of Black Ace 1 that Black Ace 1 was receiving text
messages from Aldrich.256 John Doe recalled that he walked to the front of the
line away from Aldrich, ordered and picked up his food, and left the restaurant
alone.257 John Doe recalled that after leaving, he received a text message from
Aldrich asking John Doe where he went.258 John Doe said that he received texts
from Aldrich for one or two hours after leaving the restaurant.259 John Doe
stated that he did not respond to the text messages and later told Aldrich he
had turned off his phone.260
John Doe also stated in his interview that he later spoke to Black Ace 1 about
Aldrich.261 John Doe recalled that he told Black Ace 1 that Aldrich tried to
touch him.262 John Doe recalled that Black Ace 1 responded that Aldrich was
a “creep” and then ended the conversation.263 When interviewed, Black Ace 1
stated that he did not recall speaking to John Doe about Aldrich in 2010 or at
any time.264 Prior to his interview, on July 14, 2021, Black Ace 1 sent an email
to our investigative team, in which he wrote, “I was never there to witness any
allegations, but I do remember [John Doe] talking to Jim Gary at the time about
it.”265 John Doe’s conversation with Jim Gary is described below in Section
VII.B.3.
Aldrich stated that he did not perceive interactions between him and John Doe
to be awkward in the days after the sexual encounter. Aldrich stated that he
and John Doe continued to socialize at bars.266 Phone records reflect that,
between May 10 and May 30, Aldrich called or attempted to call John Doe ten
times, and John Doe called or attempted to call Aldrich three times.267 The
phone records indicate that none of these phone calls were longer than three

34
minutes, and several calls were only one minute in duration268—which could
indicate no connection was made or a voicemail was left.i
F. John Doe’s Later Recitations of the Encounter with Aldrich

John Doe, the confidant, Aldrich, and the woman are the only individuals who
described to us in any detail their understanding of the encounter based on a
recollection at or close to the time of the encounter. There were a few
witnesses, however, that described conversations with John Doe some months
or years later in which John Doe or others in John Doe’s presence discussed
John Doe’s interactions with Aldrich. We provide those details here. We will
describe the Blackhawks’ knowledge of what occurred between Aldrich and
John Doe in Section VII, below.
A member of the 2010-2011 Blackhawks team recalled that in September
2010, the night before the start of the Blackhawks’ training camp for the
following season, the player overheard John Doe tell a story to other players
about John Doe, Black Ace 1, and a woman participating in a “threesome,” and
Aldrich trying to join.269 The player further recalled overhearing John Doe or
Black Ace 1 say that Aldrich tried to touch the genitals of one of the players
involved in the “threesome.”270 The player stated that John Doe and Black Ace
1 told the story in a joking manner and that it did not seem like a serious issue
to the player.271
A former player for the Rockford IceHogs recalled speaking to John Doe during
the IceHogs’ season-ending party in the spring of 2011.272 The IceHogs player
recalled that John Doe pulled him aside and told him about an incident that
occurred between John Doe and the Blackhawks’ video coach during the 2010
playoffs.273 The IceHogs player recalled thinking that others knew about the
incident because John Doe did not appear to be discreet during the
conversation.274 The IceHogs player recalled that John Doe told him that,
when he was a Black Ace during the 2010 playoffs, he was drinking and
hanging out with the Blackhawks’ video coach.275 The IceHogs player further
recalled that John Doe said that John Doe and the video coach were watching

iFor this information, we relied on call logs for Aldrich’s Blackhawks-issued

cell phone; call logs associated with Aldrich’s personal phone and text
messages were not available.

35
pornography and the coach performed oral sex on John Doe.276 The IceHogs
player recalled that John Doe then said John Doe pushed the video coach off of
him.277
A former roommate of John Doe stated in his interview that in 2011 or 2012,
John Doe told the roommate that there was a sexual incident involving
someone from the Blackhawks.278 The roommate recalled that John Doe
seemed uncomfortable during the conversation and did not want to share all
of the details about the incident, so the roommate did not ask many
questions.279
G. Aldrich’s Interactions with Black Ace 1

John Doe’s May 7, 2021 Complaint alleged that prior to the alleged sexual
assault on John Doe, the Blackhawks were made aware that Aldrich had
sexually assaulted a teammate of John Doe (a point denied by all witnesses
who were in senior management).280 Many witnesses told us they knew or
believed that the teammate was Black Ace 1.281 When interviewed, Black
Ace 1 reported several specific interactions with Aldrich during the 2010
playoffs. He denied that he had any direct sexual encounters with Aldrich.282
Aldrich also denied any direct sexual encounters involving Black Ace 1.283
Black Ace 1 recalled that at some point early in the 2010 playoffs, Aldrich came
out to Black Ace 1 as gay.284 After this conversation, Black Ace 1 recalled
receiving a text message in which Aldrich said he could give a better “blow job”
than any woman could.285 When the team was in San Jose (May 12 to 19),
Aldrich invited Black Ace 1 to Aldrich’s hotel room where a female masseuse
gave Black Ace 1 a massage and a “hand job” in the bathroom while Aldrich sat
on the bed in the bedroom.286 On May 21 or May 23, 2010, Black Ace 1 recalled
receiving a text message from Aldrich that included a photograph of a penis.287
Black Ace 1 recalled that Aldrich followed up with a second text message in
which Aldrich said the photograph was intended for a different person.288
During his interview, Black Ace 1 said that he thought he was the only person
Aldrich was “doing this to” during the 2010 playoffs.289 Aldrich stated when
interviewed that he did not recall sending these text messages to Black Ace 1
during the 2010 playoffs, but also noted that he did not recall with certainty
that this did not happen.290
Black Ace 1 stated that a Front Office employee was standing next to him when
he received the text with the explicit photograph.291 The Front Office

36
employee was close with Black Ace 1 at the time.292 We refer to her
throughout this report as Employee A.293 Black Ace 1 recalled that Employee A
pushed him to tell someone about the text from Aldrich, believing that the text
was inappropriate and especially so coming from a coach to a player.294
When interviewed, Employee A confirmed that she spoke to Black Ace 1 about
a picture of a penis that Aldrich texted to Black Ace 1, and then a follow-up text
from Aldrich expressing that the text was intended for a different person.295
Employee A recalled speaking with Black Ace 1 about the explicit text message
in the Front Office after Black Ace 1 came upstairs from skating.296
Employee A confirmed that she told Black Ace 1 that he should tell someone.297
Employee A also stated that she told a male Hockey Operations employee
about the texts Black Ace 1 received from Aldrich;298 that conversation is
described in detail below in Section VII.B.1. Employee A recalled hearing from
Black Ace 1 at a later time that Black Ace 1 did not want to be around Aldrich,
that Aldrich continued to call Black Ace 1, and that Black Ace 1 told Aldrich to
stop contacting him.299
Black Ace 1 vehemently denied to us in writing and during his interview that
he had any direct sexual encounters with Aldrich.300 On April 18, 2011, an
individual who we will refer to as a professional acquaintance of Black Ace 1
wrote an email to the Executive Director of the NHLPA, Donald Fehr.301 The
acquaintance wrote:
“I know you have spoken with [John Doe’s confidant] regarding
an incident with [John Doe] and a Chicago staff member during
the Stanley Cup Playoffs last year. [Black Ace 1] was involved as
well and I got him in touch with [a therapist affiliated with the
NHLPA] approximately 2 weeks ago; however, I did want to
have a follow up with yourself.”302
When interviewed, Black Ace 1’s acquaintance stated that he did not recall
sending this email or Black Ace 1 telling him that an incident involving Aldrich
had occurred.303 The acquaintance also stated that he did not recall speaking
to Fehr about an incident involving Black Ace 1 and Aldrich.304 The
acquaintance speculated that, based on this email and in his view, an incident
involving Black Ace 1 and Aldrich must have occurred; however, he was not
certain that it did.305 The acquaintance also stated that Black Ace 1 recently

37
(in 2021) sent him an email vehemently denying any sexual interaction with
Aldrich occurred in 2010.306
The communication made by John Doe’s confidant to the NHLPA is described
further in Section IX.B below.
In 2010, rumors of an incident between Black Ace 1 and Aldrich started and
followed Black Ace 1 for years. Black Ace 1 recalled being asked by a couple
of players about whether Aldrich gave Black Ace 1 a “blow job.”307 Black Ace 1
recalled laughing off the question and saying “no.”308 A former coach for the
Rockford IceHogs wrote in a 2011 evaluation of Black Ace 1, “I think what
happened last spring with Brad Aldrich weighed on [Black Ace 1] this year big
time.”309 When interviewed, the former coach stated that he never spoke to
Black Ace 1 about Aldrich and based the note in the evaluation on rumors he
heard at the time.310 Black Ace 1 also recalled an incident in approximately
2014 when he was chased around the ice by a former Blackhawks player who
called Black Ace 1 a “f****t” and asked if Black Ace 1 “liked that blow job or
what?”311
Based on the available evidence, it is difficult to discern precisely what
occurred between Aldrich and Black Ace 1; both individuals denied in
interviews that anything occurred other than the explicit text messages Black
Ace 1 recalled receiving from Aldrich during the 2010 playoffs. Clearly, other
individuals, including Black Ace 1’s coach and later a professional
acquaintance who wrote an email to the NHLPA, believed something occurred
and expressed concern. We include this information about Black Ace 1
because it is clear, at a minimum, that Aldrich, a coach, sent Black Ace 1, a
minor league player, text messages of a sexual nature during the 2010 playoffs
around the same time as the encounter between John Doe and Aldrich.
***
Next we turn to describing what the Blackhawks knew about the encounter
between John Doe and Aldrich, when they knew it, and what they did upon
learning the information.
VII. The Blackhawks’ Knowledge of What Occurred

In this section, we describe the extent to which Blackhawks coaches, staff, and
other non-player personnel, including senior management, were informed of
a sexual encounter involving Aldrich and John Doe during the 2010 playoffs.

38
This section begins with John Doe sharing information with a Blackhawks
skating coach. We then describe events in Chicago from May 21 through 23,
including conversations that occurred between John Doe, Black Ace 1, Jim
Gary, and a key meeting among senior management and the Blackhawks’ Head
Coach, Joel Quenneville, within an hour of the Blackhawks winning the
Western Conference Finals.
A. San Jose (May 12 to 19)

The Blackhawks arrived in San Jose on May 12 from Vancouver and left San
Jose on May 19.312 John Doe, Black Ace 1, and other Black Aces took a
commercial flight from Chicago to San Jose on May 12.313 The Black Aces,
including John Doe, departed San Jose with the team on May 19.314

John Doe recalled that, while in San Jose, the first person he spoke to about the
encounter with Aldrich was Paul Vincent, then a Blackhawks skating coach.315
John Doe’s confidant recalled that John Doe told him that Vincent observed
John Doe seeming distraught and having “nothing in him” while skating or
working out, and John Doe and Vincent then spoke about Aldrich.316 John Doe
recalled that Vincent said he had heard “something through the grapevine”
and asked John Doe a direct question about Aldrich.317 John Doe recalled
telling Vincent that he could “confirm that.”318 John Doe further recalled that
Vincent then asked John Doe what happened and John Doe responded, “I don’t
know.”319 John Doe said that Vincent told John Doe that this was all Vincent
needed, that he would handle it, and he would take the issue to the “proper
people.”320 Vincent’s description of this conversation and related events are
described further in Section VII.D below.

39
 B. Chicago (May 19 to 23)

The Blackhawks traveled to Chicago on May 19, practiced on May 20, played
Game 3 at home against San Jose on May 21, and played Game 4 at home
against San Jose on May 23.321 The San Jose series ended on May 23 with a
Blackhawks victory.322

As described in more detail below, there is a wide variety of witness accounts

about the events of May 21 to 23. There is consistency in the accounts,
however, that Al MacIsaac (Senior Director of Hockey Administration) heard
something had occurred involving Aldrich and John Doe, dispatched Jim Gary
to speak to John Doe about what had happened, and thereafter a meeting
occurred with senior management. The meeting occurred in John
McDonough’s office within an hour of the Blackhawks winning the Western
Conference Finals. Although there are varying accounts of what was said
during the May 23 meeting, almost all of the participants in the meeting recall
learning about an incident involving Aldrich and John Doe. After the meeting,
no one contacted Human Resources, the information was not explored further
through a formal investigation or otherwise, and Aldrich continued to serve as
a video coach, travel with the team, and be present for team activities until his
separation from the organization on June 16. The details of these events
follow.
1. Conversations with Employee A

The first series of conversations regarding Aldrich that occurred in Chicago

after the team’s return from San Jose involved Employee A.323 In addition to
speaking to Black Ace 1 about explicit text messages he received from Aldrich,
when interviewed, Employee A recalled learning from Black Ace 1 that
something sexual and physical had happened between John Doe and
Aldrich.324 Employee A recalled that Black Ace 1 told Employee A that John

40
Doe was extremely upset.325 During her interview, Employee A stated that she
spoke to John Doe about the incident and recalled thinking at the time that he
was being evasive and seemed embarrassed to share the details of what
occurred.326 In interviews, neither John Doe nor Black Ace 1 said they
remember having a conversation with Employee A about a sexual encounter
between John Doe and Aldrich.327
Aldrich recalled that after the sexual encounter with John Doe, and while he
was still employed with the Blackhawks, he heard a rumor that Employee A
found out that Aldrich and John Doe had a sexual interaction and further heard
that Employee A was upset by this information.328
2. Conversations with Al MacIsaac

In an interview, Employee A stated that upon hearing from Black Ace 1 and
John Doe about Aldrich, and before the 2010 season ended, Employee A told a
male Hockey Operations employee that a physical incident had occurred
between Aldrich and John Doe, that Black Ace 1 had received a graphic
photograph in a text message from Aldrich, and that Aldrich was harassing
Black Ace 1.329 Although Employee A declined when interviewed to share the
name of the individual with whom Employee A spoke, she also stated that it
was possible the individual was Al MacIsaac. It became clear through the
course of our investigation that MacIsaac was at least one individual Employee
A spoke to regarding Aldrich.330
When interviewed, MacIsaac recalled that on the morning of May 23, he was
sitting in his office at the United Center.331 This was the morning of Game 4 of
the San Jose series, a game that began at 2 p.m. Central Standard Time.332
MacIsaac recalled that Employee A came to his office and told him about
Aldrich.333 MacIsaac stated in his interview that he remembered the
conversation as if it happened yesterday.334 MacIsaac recalled that
Employee A told him that people were at a bar across the street, people went
back to the hotel, and at the hotel, Aldrich tried to “get under the sheets with”
John Doe.335 MacIsaac stated that he did not know where Employee A learned
the information Employee A shared with MacIsaac, or why Employee A told
him.336 MacIsaac stated that, in his view, Employee A was not asking MacIsaac
to take action.337 MacIsaac was unclear as to whether Employee A referenced
Black Ace 1 during the conversation.338

41
MacIsaac stated that he recalled feeling shocked because he had previously
seen Aldrich “hit on” his female assistant and the story about Aldrich and John
Doe therefore did not make sense to him.339 MacIsaac stated that he recalled
thinking that it was inappropriate for a player and coach to be socializing.340
MacIsaac further stated that he recalled thinking that the issue with Aldrich
needed to be addressed.341 He stated that he reached out to Jim Gary and
asked Gary to find out what happened between John Doe and Aldrich.j, 342
Gary recalled during his interview that MacIsaac approached him on the
afternoon of May 23 and asked to speak to him privately.343 Gary recalled that
he and MacIsaac went into the hallway outside the executive game suite at the
United Center, where MacIsaac told Gary that a staff member, whom MacIsaac
did not identify, indicated that John Doe and Black Ace 1 were receiving
invitations for sex from Aldrich.344 Gary recalled that MacIsaac asked Gary to
“check it out” and speak to the two players.345
3. John Doe’s and Black Ace 1’s Conversations with Jim Gary

John Doe recalled that in the middle of a period during Game 3 or Game 4 of
the San Jose series (May 21 or 23), he received a phone call or text message
from Jim Gary.346 John Doe stated that Gary asked John Doe to meet Gary

jPhone records reflect a series of phone calls that occurred the previous day.
On May 22, at 3:27 p.m., Jim Gary called John Doe and spoke to him by
telephone for 26 minutes. Within minutes of this call ending, Gary spoke to
MacIsaac for 5 minutes and Gary then spoke to McDonough for 13 minutes.
Gary regularly spoke to Blackhawks players between game days and
McDonough, MacIsaac, and Gary were in frequent contact with each other
about a variety of topics. None of the witnesses who participated in these
phone calls—including Gary and John Doe—recalled the subject of the calls or
whether the calls were regarding Aldrich. We note the calls in this report
because of the length of the call between Gary and John Doe (26 minutes), and
because of the proximity of that call to the calls between Gary, McDonough,
and MacIsaac. All other evidence points to MacIsaac, Gary, and others first
learning about the incident involving Aldrich on May 23, not May 22 when this
sequence of phone calls occurred. For completeness, however, we note the
calls here.

42
outside of the locker room.347 John Doe stated that he went to the locker room
and saw Gary, who told John Doe to come with him because they needed to
talk.348 John Doe recalled that Gary showed John Doe through the locker room,
up a ramp, past bleachers, through the gym, through another door, and
through a short hallway before the two reached a storage closet, which was
where John Doe and Gary spoke.349 John Doe recalled that the closet stored
materials for game promotions.350 Gary recalled a somewhat similar series of
events—he went downstairs after speaking to MacIsaac and saw John Doe in
the hallway.k, 351 Gary asked John Doe if the two of them could speak and John
Doe agreed.352 Gary recalled that the rooms in which he typically met with
players were occupied, so he and John Doe spoke in a supply closet.353 Gary
recalled the closet had supplies, bottles, cans, and mops in it, and that it was a
room just off of the hallway.354
John Doe recalled that Gary told John Doe that “we heard some serious things”
and then asked if John Doe knew if Black Aces had contact with Aldrich or if
John Doe knew if anything had occurred with Aldrich.355 John Doe recalled
responding that he did not know about others, but something happened to
him.356 John Doe stated that he then told Gary the entire story of the sexual
encounter with Aldrich.357 John Doe recalled that Gary told John Doe that
“everything was going to be okay,” that John Doe was going to be “okay,” and
that Gary had to leave for a meeting.l,358 John Doe recalled that the
conversation lasted 20 to 30 minutes.359

k John Doe, through his attorney, provided permission to ask Gary (a

counselor) questions about the substance of Gary’s conversations with John
Doe in 2010 regarding Aldrich. John Doe’s attorney and the Blackhawks’ civil
litigation counsel were present for our interviews of Gary.
lJohn Doe’s confidant recalled speaking to John Doe soon after John Doe’s
conversation with Gary. The confidant recalled that John Doe recounted Gary
saying that John Doe would not “speak a word of this,” that John Doe should
“absolutely drop this,” and that John Doe had some fault for the encounter with
Aldrich occurring. In this regard, John Doe’s recollection about his
conversation with Gary is different from what the confidant stated John Doe
told him shortly after the conversation with Gary occurred.

43
In his interview, Gary recalled telling John Doe that he heard from MacIsaac
about a staff member informing MacIsaac that John Doe received an invitation
for sex from Aldrich.360 Gary recalled that John Doe became very nervous.361
Gary recalled that John Doe told Gary he was going to come to Gary about this
issue, but had not done so yet.362 Gary stated John Doe then told Gary that
Aldrich was pressuring John Doe to have sex with him and that Aldrich told
John Doe that if John Doe did not give in, Aldrich could hurt John Doe’s
career.363 Gary recalled sensing that Aldrich’s statement about his career
concerned John Doe.364 Gary further recalled John Doe stating that he
responded to Aldrich that he was not into “that stuff.”365 Gary stated that he
asked John Doe what John Doe had experienced, and John Doe responded that
Aldrich kept pressuring him, but that John Doe did not have a direct physical
encounter with Aldrich because he was not “into it.”366 Gary recalled that he
believed what John Doe told him, both about Aldrich’s efforts to pressure John
Doe into sex and Aldrich’s threats to harm John Doe’s career.367
Gary then recalled telling John Doe that this was serious and inappropriate and
that John Doe needed to tell management or Human Resources, explaining to
John Doe that “this had to come out” and that “this can’t continue.”368 In Gary’s
view, John Doe seemed very nervous and was shuffling around.369 Gary said
that John Doe was resistant to tell management and asked if Gary would tell
management first.370 Gary recalled that John Doe said he would speak to John
McDonough after Gary told management.371 Gary next recalled that John Doe
stated he did not want to be around Aldrich.372 In Gary’s memory, the
conversation lasted eight to ten minutes.373
After the conversation with John Doe ended, Gary said he left the supply closet
and approached Black Ace 1, who was standing in the hallway.374 Gary
recalled that Black Ace 1 was not receptive to speaking to Gary about Aldrich
and that the two spoke for three or four minutes in the hallway.375 Gary stated
that he asked Black Ace 1 if Aldrich had pressured him to have sex.376 Gary
recalled Black Ace 1 stating that he did not know anything about it, laughing,
and saying that it was “not his thing” before walking away.377 When
interviewed, Black Ace 1 said he met Gary outside the arena during a home
playoff game and mentioned receiving a text from Aldrich containing a
photograph of a penis.378
John Doe recalled that, after his conversation with Gary, he returned to the
press box to watch the remainder of the game.379 After the game, John Doe

44
went downstairs and waited outside the locker room to make sure he was not
needed and to receive his schedule for the next day.380 John Doe recalled
receiving multiple texts from Aldrich asking John Doe if John Doe told anyone
about what had occurred between them.381 John Doe further recalled that
Aldrich told John Doe that there was a “huge meeting” in the coaches’ office
and that the coaches kicked Aldrich out of the meeting.382 No witnesses
identified a coaches’ meeting occurring after a San Jose playoff game in which
Aldrich was kicked out of the meeting.
4. The Executive Game Suite

Gary recalled that he returned to the executive game suite and told MacIsaac
that the issue needed to be looked into and that it was a potentially serious
problem.383 Gary recalled that MacIsaac said he would get back to Gary and
about fifteen to twenty minutes later, while the game was still being played,
MacIsaac came back to Gary and told Gary that they would meet in John
McDonough’s office after the game.384
When interviewed, MacIsaac recalled being in the executive game suite during
Game 4 (May 23) with Stan Bowman, John McDonough, then-assistant general
manager Kevin Cheveldayoff, and then-senior vice president Jay Blunk.385
MacIsaac recalled that during the game, Jim Gary entered the suite, and then
MacIsaac, Gary, and Bowman spoke in the hallway outside the suite.386
MacIsaac stated that Gary told Bowman and MacIsaac that there was
“something to it” (with regards to the information Employee A told
MacIsaac).387
When interviewed, Bowman recalled that after Game 4 ended—which was at
approximately 4:46 p.m. Central Standard Time—MacIsaac approached him
in the executive game suite.388 Bowman recalled MacIsaac stating that there
was a problem with Aldrich and John Doe, and they needed to speak with
McDonough.389 Bowman said he may have spoken to Gary as well, but he did
not specifically recall doing so.390 Bowman said he recalled feeling surprised
by what MacIsaac told him because the Blackhawks had just won and Bowman
usually went directly to the locker room after games to speak with the
coaches.391

45
 5. John McDonough’s Office

After Game 4 ended, a meeting occurred in John McDonough’s office in the

Front Office space at the United Center. Jim Gary, Stan Bowman, Al MacIsaac,
John McDonough, Kevin Cheveldayoff, and Jay Blunk were present. The
participants recalled the meeting lasting for between ten and twenty-five
minutes.392 After the meeting started, Bowman recalled McDonough saying
that Quenneville should participate because the incident involved Aldrich, a
coach.393 Quenneville was subsequently called to the Front Office to join the
meeting.394 When interviewed, Quenneville stated that being called into a
meeting in McDonough’s office was unusual since the game had just ended.395
As noted earlier, there are multiple and sometimes different recollections of
what occurred during the meeting in McDonough’s office. As this is a critical
meeting in the course of the events that occurred, and to be fair to all involved,
we describe below what each participant in the meeting recalled.
a. Jim Gary

Gary recalled during his interview that he told the assembled group in
McDonough’s office what John Doe told him: that Aldrich was pressuring John
Doe for sex, that John Doe told Aldrich he was not “into that,” and that Aldrich
threatened John Doe by saying if John Doe did not comply, Aldrich could hurt
John Doe’s career.396 Gary recalled that he also expressed that John Doe was
uncomfortable around Aldrich due to the situation.397 Gary recalled the
participants seemed to be stunned.398 He recalled that the participants started
to discuss what to do next, including someone mentioning the possibility of an
investigation into the matter.399 Gary stated during his interview that he
believed he heard someone ask if they should involve the Director of Human
Resources.400 Gary recalled that he told the group that it was important for
them to speak to John Doe and McDonough stated he would speak to John
Doe.401 Gary further recalled asking if the group needed him, the group saying
no, and Gary leaving the meeting before it ended.402 Gary stated that when he
left the room, he told the group to let him know what happened so that he
could inform John Doe of the outcome.403 Gary recalled that someone said they
would get back to him.404

46
 i. Gary’s Description of the May 23 Meeting to
the Director of Human Resources in 2021
In a January 2021 conversation with the Director of Human Resources and
another individual, Gary provided additional details about the meeting in
McDonough’s office that went beyond the details he recalled during our
interview. In particular, according to the Director of Human Resources, Gary
said that during the meeting, Quenneville appeared angry and was concerned
about upsetting team chemistry. Also according to the Director of Human
Resources, Gary recalled that “they” decided to hold off talking to Aldrich
about the situation until the season was over.405
b. Stan Bowman

Bowman recalled that, during the May 23, 2010 meeting, either MacIsaac or
Gary stated that there was an incident between John Doe and Aldrich in which
Aldrich had tried to “climb into bed” with John Doe one night at Aldrich’s
apartment.406 Bowman recalled that Gary said he had spoken to John Doe
earlier that day and that John Doe did not want to talk about it.407 Bowman
told us that, as described to him, the situation did not strike him as
immediately alarming at the time as the allegation did not involve a sexual
assault as having occurred.408
Bowman recalled that, after learning of the incident, Quenneville shook his
head and said that it was hard for the team to get to where they were, and they
could not deal with this issue now.409 Bowman further recalled that
McDonough referenced his previous employment with the Chicago Cubs.410
Bowman recalled McDonough saying that the Blackhawks might never make
it this far in the playoffs again, and that they needed to think about when to
handle the issue.411 (The Blackhawks had not played in the Stanley Cup Finals
in 18 years.) Bowman did not recall anyone explicitly referencing the notion
that the issue should be tabled until after the playoffs.412 Rather, Bowman
recalled discussion about the need to find out more about what happened.413
Bowman further recalled that he asked McDonough what McDonough wanted
to do and McDonough responded that Bowman should leave it to
McDonough.414 Bowman stated that when the meeting ended, Bowman
believed the issue was in McDonough’s hands and everyone else should focus
on the upcoming Stanley Cup Finals.415

47
 c. Al MacIsaac

In his interview, MacIsaac recalled that Gary told the group that Aldrich had
tried to “get under the sheets” with John Doe.416 MacIsaac stated that he
believed at the time that something inappropriate had happened between a
player and a coach, but he did not think a crime had occurred, and he believed
that the issue would be taken care of when the season ended.417 MacIsaac
remembered little else about the meeting, including how it ended and what
was to occur following the meeting related to the incident.418

i. MacIsaac’s Description of the May 23

Meeting to a Blackhawks Employee Several
Years Later

A Blackhawks employee we interviewed recalled speaking to MacIsaac about

Aldrich several years after the 2010 meeting in McDonough’s office.419 The
employee recalled that MacIsaac recounted how he learned during the 2010
playoffs that John Doe and Black Ace 1 were with a woman when Aldrich tried
to, in MacIsaac’s words, “force” himself onto, and perform oral sex on, one of
the players, but the player shoved Aldrich away.420 The employee further
recalled that MacIsaac told him that McDonough did not want any negative
publicity during the Stanley Cup Finals, which was why the Blackhawks waited
until after the playoffs to separate Aldrich from the organization.421 When
asked about these statements, MacIsaac stated that he had no recollection of
speaking with the employee about Aldrich—not several years after the May 23
meeting or ever.422

d. John McDonough

McDonough recalled that Jim Gary told the group that he was “aware of an
incident” and John Doe “was embarrassed about the incident.”423 McDonough
also stated during his interview that he believed Gary explained during the
May 23 meeting what occurred, but he could only recall that Gary mentioned
Aldrich’s name and how the situation was embarrassing for John Doe.424
In his initial interview, McDonough denied that there was a discussion during
the meeting about who was going to address the issue or about tabling the
issue until after the playoffs.425 McDonough recalled that Quenneville
appeared to be agitated.426 McDonough otherwise had virtually no

48
recollection of the discussion after the issue had been raised.427 During a
second interview, McDonough stated that Gary told the assembled group that
Gary was going to address the issue with John Doe again following the
meeting.428 The next event McDonough recalled was that the meeting ended
and everyone dispersed.429 McDonough stated that this was the first and last
time he recalled discussing this issue.430
i. McDonough’s Description of the May 23
Meeting to the Director of Human Resources
on June 14, 2010

According to the then-Director of Human Resources, three weeks later, on June

14, McDonough called the Director into his office and told her that he learned
of an incident a few weeks earlier involving Aldrich.431 The Director of Human
Resources recalled that McDonough told her that the incident involved
drinking and Aldrich “hitting on” or making a sexual advance on John Doe at
an off-site apartment.432 The Director of Human Resources also recalled
McDonough describing the meeting in his office on May 23 after Game 4 ended
with MacIsaac, Bowman, Gary, and Quenneville.433 The Director of Human
Resources recalled that McDonough told her that, during the meeting, the
group decided not to alert Human Resources or outside legal counsel and to
not do anything about the incident during the playoffs so as not to “disturb
team chemistry.”434 The Director of Human Resources further recalled
McDonough saying that the group decided to keep the alleged incident among
themselves for the duration of the playoffs and that they would address the
issue as soon as possible after the season.435
The Director of Human Resources also recalled McDonough referencing the
fact that John Doe was physically larger than Aldrich.436 When interviewed,
McDonough made the same comment, adding that it was hard for him to
imagine that a non-consensual sexual encounter occurred between John Doe,
who McDonough believed to be 6’3” and 230 lb. in 2010, and Aldrich, who
McDonough believed to be 5’6” and 130 lb. in 2010.437
When interviewed, McDonough stated that he did not recall speaking with the
Director of Human Resources about Aldrich on June 14 or at any time.438

49
 e. Joel Quenneville

During his interview, Quenneville generally recalled a meeting in

McDonough’s office after Game 4 of the San Jose series with members of the
Blackhawks’ senior management.439 Other participants in the meeting
recalled that Quenneville was not present for the first portion of the meeting
and was called upstairs to the Front Office to join the meeting after it had
started.440 Quenneville recalled others in the meeting stating that “an event
happened without saying what happened” and that “something may have
happened.”441 When interviewed, Quenneville stated that he believed that the
issue being discussed involved a coach doing something improper and that the
group was meeting to decide whether to “make it public.”442 Quenneville also
stated that he did not believe that John Doe’s name was referenced and, after
multiple interviews, Quenneville was unclear whether Aldrich’s name was
referenced.443
Quenneville also said when interviewed that he did not recall anyone saying it
was hard for the team to get where they were in the playoffs, but recalled that
his focus was on winning and this meeting was unexpected.444 He said that
there was no resolution of the situation at the meeting.445
Otherwise, Quenneville recalled nothing else regarding the meeting or the
events more broadly.
f. Kevin Cheveldayoff

Kevin Cheveldayoff, then the Assistant General Manager, recalled that there
was a meeting in McDonough’s office before a home game during the
Philadelphia series (the Stanley Cup Finals), and not the San Jose series.446
Regardless of when Cheveldayoff believed the meeting occurred, Cheveldayoff
recalled being in a meeting in McDonough’s office regarding Aldrich with
others in senior management, including McDonough, Bowman, MacIsaac, and
Quenneville.447 He recalled the group was told that there were allegations that
Aldrich was socializing with players outside the arena, Aldrich sent
inappropriate texts to players, and Aldrich made unwanted advances on
players.448 Cheveldayoff recalled that John Doe and Black Ace 1 were
specifically referenced during the meeting.449 Cheveldayoff also recalled that
he felt shocked at the time because it was not common for coaches and players
to socialize, and he believed at the time that the allegations were serious.450

50
He further recalled someone stating that the allegations needed to be
investigated and that someone would make sure the two players and Aldrich
would be kept separate.451 Cheveldayoff recalled no other substantive details
from the meeting.
g. Jay Blunk

Jay Blunk, then a Senior Vice President and present for the meeting in
McDonough’s office, recalled someone saying that Aldrich may have
propositioned a player, who Blunk believed was identified during the meeting
as John Doe.452 Blunk recalled that someone said they were going to look into
the issue and substantiate it.453 Blunk recalled no other substantive details
from the meeting.
6. Jim Gary’s Phone Calls with Stan Bowman and Joel
Quenneville

During the late evening of May 23, several hours after Game 4 and the meeting
in McDonough’s office, Gary recalled speaking to Bowman by telephone about
the Aldrich situation.454 Phone records reflect a 19-minute phone call between
Bowman and Gary on May 23 starting at 9:06 p.m.455 Gary recalled that he
spoke to Bowman to confirm that the Blackhawks were going to pursue an
investigation.456 When interviewed, Gary said that he knew John Doe was
hurting and he wanted to confirm the Blackhawks were following through in
a timely fashion.457 Gary recalled Bowman stating that the group in the
meeting discussed the issue and that they “will pursue this,” including by
questioning Aldrich, and they would bring it to “an ending.”458 Gary recalled
feeling reassured by Bowman during the phone call.459 Bowman did not recall
this phone call, but did not deny that it could have happened and could have
involved a discussion regarding Aldrich.460
The following day, phone records reflect that Gary called Quenneville at 12:49
p.m. and the call lasted for 10 minutes.461 Quenneville did not recall this phone
call or what they discussed, and speculated that the conversation could have
been about a different topic, such as a family member who had spoken with
Gary as a counselor on a prior occasion.462 Quenneville also stated that he and
Gary typically met once annually. Available phone records reflect no other
phone calls between Gary and Quenneville in 2010.463

51
 7. Contacts with the Blackhawks’ Management by John Doe’s
Confidant

John Doe’s confidant stated that he called Stan Bowman or Al MacIsaac, or

possibly both individuals, regarding Aldrich.464 The confidant was uncertain
as to when the contacts were made, and stated that the contacts could have
been in May or June 2010, as late as early 2011, or at both times.465 We were
unable to corroborate the confidant’s contacts with Bowman or MacIsaac with
phone records, although not all relevant phone records exist today. The
confidant recalled that he told Bowman or MacIsaac that there was an incident
with Aldrich, it was of a “disgusting sexual variety,” and John Doe was a
“mess.”466 The confidant stated that Bowman or MacIsaac told him that they
would look into the information the confidant shared and “handle it.”467
Bowman and MacIsaac stated in interviews that they did not recall speaking
to the confidant about Aldrich at any time, although Bowman stated that it is
possible he spoke to the confidant about Aldrich and has no memory of it.468
C. Blackhawks 2009-2010 Players

Two former Blackhawks players claimed in their interviews and publicly in

2021 that, during the 2010 playoffs, “everyone” knew about Aldrich engaging
in inappropriate conduct with players.469 In particular, Brent Sopel claimed in
his interview and publicly that “everyone” was talking about how Aldrich
wanted to “touch penises” during the 2010 playoffs and that “everyone”
knew.m, 470 Nick Boynton stated in his interview and publicly that during the
2010 playoffs, numerous Blackhawks players asked him what happened
regarding Aldrich.471 We pressed Sopel and Boynton for details regarding
which conversations, and with whom, led them to believe that “everyone”
knew about Aldrich engaging in inappropriate conduct with players.472
Neither Boynton nor Sopel could provide many details.473 Interviews of
players from the 2010 Blackhawks’ roster contradicted the claims that
“everyone” knew—of the 14 players on the 2010 roster whom we interviewed,
6 players told us they had no knowledge of inappropriate conduct by Aldrich

m Former Blackhawks players Brent Sopel and Nick Boynton publicly

identified themselves in 2021 and made public statements about their
knowledge of certain events.

52
in 2010, and 6 players told us they only learned about inappropriate conduct
through rumors after Aldrich separated from the Blackhawks in June 2010.474
Two players—Sopel and Boynton—stated that they heard about
inappropriate conduct by Aldrich before he separated from the team.475
D. Paul Vincent

As noted in Section VII.A. above, John Doe recalled that he provided some
information about Aldrich to Paul Vincent, the skating coach, while the team
was in San Jose between May 12 and 19.476 When interviewed, Vincent stated
that while the details are “cloudy,” he recalled hearing about an issue involving
two players and Aldrich.477 Vincent recalled hearing about the issue from a
2010 Blackhawks player, Nick Boynton, while the team was in San Jose.478
Boynton recalled speaking to Vincent about how he heard that Aldrich asked
two players if Aldrich could “jerk them off” and that the encounter involved
drugs and alcohol.479 Boynton stated that when he and another player spoke
to Vincent, Vincent said he would take care of it.480 The other player did not
recall a conversation with Boynton about Aldrich, and stated that he did not
speak to Vincent about Aldrich.481 A third 2010 Blackhawks player, Brent
Sopel, stated when interviewed that Vincent approached him sometime while
the team was in San Jose, and told him about Aldrich wanting to touch two
players’ genitals.482
Vincent said he approached the two players who had been identified to him,
whom he declined to identify to us during our investigation. It appears that
Vincent was referring to John Doe and Black Ace 1.483 Vincent stated that the
two players told Vincent that they were recently at Aldrich’s apartment on the
same or different occasions and Aldrich tried and wanted to touch the genitals
of one or both players, but the two players resisted.484 Vincent stated that he
told the two players that the information they provided was all he needed to
know and that he did not need to hear more.485 Vincent stated that he told the
two players that he would alert the appropriate people who could handle the
situation.486 When interviewed, Black Ace 1 categorically denied ever having
a sexual encounter with Aldrich or speaking to Vincent about Aldrich at any
time.487
Vincent said that after he spoke to the two players, he approached Jim Gary
and Brian Higgins—a United Center security person—while the team was in
San Jose.488 Vincent said that he shared with Gary and Higgins what the two

53
players told him regarding Aldrich, and stated to us that he was particularly
confident he had spoken to Higgins.489 Vincent further stated that he was
asked to join a meeting with McDonough, Bowman, MacIsaac, and Gary in a
meeting room at the team hotel in San Jose.490 He stated that he told the group
what the two players told him regarding Aldrich.491 Vincent stated that
MacIsaac said they were handling the situation, and that Vincent told the
group that they should call the Chicago Police Department and have the police
quietly investigate.492 Vincent said that MacIsaac told Vincent not to worry
about the situation and that he could leave the meeting.493
Vincent said that after he left the meeting, he told two assistant coaches about
the situation before heading to dinner.494 One of the assistant coaches told us
that Vincent did not raise issues with him regarding Aldrich or a meeting with
management in San Jose, and stated that he would have recalled such a
conversation had it occurred.495 The second assistant coach, John Torchetti,
did not respond to our requests to be interviewed. Torchetti informed a
reporter in 2021 that, during the 2010 playoffs, Vincent told him about two
players confiding in Vincent regarding Aldrich, and that Vincent alerted
management.496 Boynton and Sopel told us that Vincent reported to them in
2010 that he had informed management of the situation involving Aldrich.497
Vincent’s account is directly contradicted by witnesses and records from May
2010. Brian Higgins—by all accounts and as proven by contemporaneous
records—was not in San Jose in May 2010 and stated that he never had a
conversation with Vincent about Aldrich or John Doe.498 All of the individuals
who Vincent stated he met with at the team hotel in San Jose stated
unequivocally that they did not meet with Vincent about Aldrich when the
team was in San Jose or at any time thereafter.499 And, as noted above, one of
the assistant coaches Vincent stated he told of the incident and meeting with
management denied Vincent spoke to him about either event. Based on our
investigation, we could not conclude that Vincent took the information that
John Doe provided to Vincent in San Jose and shared it with management.
***
The next section describes in detail the action, and inaction, by the Blackhawks
regarding Aldrich in the days and weeks that followed the May 23, 2010
meeting.

54
 VIII. The Blackhawks’ Response During the 2010 Playoffs and Later

In this section, we describe the events that followed the May 23 meeting. We
note that for three weeks (May 23 to June 14), it appears that no action was
taken by senior management of the Blackhawks to learn more, to notify
Human Resources, to communicate with John Doe about the incident, to
separate Aldrich from the players, or to address the information Gary received
on May 23. On June 14, five days after the Blackhawks won the Stanley Cup,
according to the Director of Human Resources, John McDonough informed her
about the situation.500 After the conversation with McDonough, according to
the Director of Human Resources, she spoke to Gary and MacIsaac, and then
met with Aldrich.501 During the meeting with Aldrich, the Director of Human
Resources and the Blackhawks’ outside counsel gave Aldrich the option to
undergo an investigation or resign, and Aldrich chose to resign.502 No further
investigation was conducted.
A. The Stanley Cup Finals

From May 23, 2010 until June 14, 2010, Aldrich continued to serve as the
Blackhawks’ video coach, traveled with the team to Philadelphia for games in
the Stanley Cup Finals, and otherwise participated in team activities. The
Black Aces, including John Doe, continued to practice and watch playoff games,
and traveled to Philadelphia for Game 6, the last game of the Stanley Cup
Finals. We found no evidence that steps were taken to learn more about the
incident involving Aldrich or to discuss the issue with John Doe or with
Aldrich. We found no evidence that there were discussions about whether it
was appropriate, based on the information known at the time, to limit
Aldrich’s contacts with Black Aces, Blackhawks players, or Blackhawks
personnel. We found no evidence that the Blackhawks’ Human Resources
Department was contacted about the incident, that an investigation was
initiated, or that any other steps were taken to pursue the information known
at the time.503
McDonough stated when interviewed that, after everyone dispersed from the
May 23 meeting in his office, he did not recall discussing the issue involving
Aldrich ever again.504 Bowman recalled MacIsaac informing him on May 24
that Employee A was the individual who brought information about Aldrich to
MacIsaac in the first instance.505 Bowman recalled no other conversations
about Aldrich and John Doe during the playoffs.506 MacIsaac stated when

55
interviewed that he did not recall having any additional conversations about
Aldrich after May 23.507
Gary recalled speaking to John Doe again on May 24 or May 25.508 Gary
recalled telling John Doe about the May 23 meeting in McDonough’s office, that
the Blackhawks would be investigating, and that Gary would let John Doe
know the outcome.509 Gary also recalled telling John Doe that the Director of
Human Resources would likely call John Doe about the investigation.510 Gary
explained when interviewed that he wanted to give John Doe some sense of
relief that the Blackhawks were working on the issue.511 Gary recalled that,
during this conversation, John Doe told him that he thought Aldrich knew
something “was up” because Aldrich was no longer looking at John Doe or
speaking to John Doe.512 Gary recalled that John Doe reiterated that he did not
want to be around Aldrich.513
Gary also recalled that several days after he first attempted to speak to Black
Ace 1 on May 23, he had a second conversation with Black Ace 1.514 Gary
recalled the conversation again taking place in the hallway of the United
Center.515 Gary stated that he again asked Black Ace 1 if he had information
regarding Aldrich pressuring him or others sexually, and Black Ace 1 said “no”
and walked away.516 Gary recalled that this was the last time he attempted to
directly discuss this issue with Black Ace 1.517
The Blackhawks played against the Philadelphia Flyers in the Stanley Cup
Finals between May 29 and June 9.518 On June 9, 2010, the Blackhawks won
the Stanley Cup.519
B. After the Stanley Cup Finals

Several witnesses recalled that Aldrich, who had not yet been investigated or
separated from the Blackhawks, celebrated with the team in the days
following the Stanley Cup win, including on June 10 when the team traveled
around Chicago with the Stanley Cup.520 Photographs corroborate that Aldrich
participated in celebrations when the team won the Stanley Cup and in the
days that followed (see Appendix). John Doe recalled that, after the team won
the Stanley Cup, he saw Aldrich on the ice and in the locker room celebrating
with the team.521 John Doe stated that seeing Aldrich in these two places
indicated to him that nothing had been done to separate Aldrich from the
players after John Doe told Gary what occurred between Aldrich and him.522

56
 1. Aldrich Touches A Blackhawks Employee

One Front Office paid intern, a male employee who was twenty-two years old
at the time, recalled when interviewed that Aldrich texted him to meet Aldrich
and the Blackhawks team for celebrations in downtown Chicago on the
evening of June 10.523 The employee recalled that he met Aldrich at the
Haymarket bar on Randolph Street at 8 or 9 p.m.524 After about an hour, the
employee recalled traveling with Aldrich and two Blackhawks players in a car
to Stanley’s, a bar in the Lincoln Park neighborhood of Chicago, staying for an
hour, and then traveling to a third bar in the Wrigleyville neighborhood of
Chicago.525 The employee recalled that, at around 1 a.m., he shared a taxi with
Aldrich and a third person.526 The taxi dropped the third person off first, and
then went to Aldrich’s apartment building to drop off Aldrich.527
The employee recalled that when he and Aldrich arrived at Aldrich’s
apartment building, Aldrich asked if the employee wanted to go upstairs to
Aldrich’s apartment for a drink.528 The employee recalled saying “no.”529 The
employee recalled Aldrich asking the employee a second time if the employee
wanted to go upstairs to Aldrich’s apartment for a drink, which the employee
again declined.530 Then, the employee recalled that Aldrich put his hand on
the employee’s “crotch” at the same time that he asked, in a suggestive manner,
if the employee wanted to go upstairs.531 The employee stated that Aldrich did
not mention anything about a drink during this third statement, and it was
clear to the employee that the request was sexual in nature.532 The employee
recalled responding “What the fuck?! No.”533 The employee recalled that
Aldrich then threw money down for the taxi and went into his apartment
building.534 The employee continued to his residence in the taxi.535 Four other
entry-level Front Office employees recalled the employee telling them directly
in 2010 that Aldrich propositioned this employee while the two were in a
taxi.536 Five other Front Office employees recalled hearing about the incident
from others in 2010.537 We uncovered no evidence that any of these nine
employees reported the incident to Human Resources.
When interviewed, the employee recalled texting Aldrich when he woke up
the next morning and questioning Aldrich’s actions in the taxi.538 The
employee recalled that Aldrich apologized and said he was drunk, that “no one
knows, please don’t tell,” and that “people like me kill themselves where I’m
from.”539 The employee understood that Aldrich was coming out to him as

57
gay.540 The employee recalled that he felt bad for Aldrich.541 The employee
recalled that his response to Aldrich was that he would not tell anyone.542
The employee stated when interviewed that he did not feel the need to report
the incident to the Blackhawks, where he was still employed at the time, and
in fact did not report the incident to Human Resources or anyone in senior
management.543 The employee further explained that Aldrich apologized and
the employee “chalked it up to a drunken mistake.”544 The employee also
recalled that he did not want to say anything about Aldrich’s proposition to
anyone, including to Blackhawks management, because the employee knew
that Aldrich’s father worked for the San Jose Sharks.545 The employee wanted
to ensure that Aldrich would serve as a reference for him for future
employment in the hockey industry and did not want to risk Aldrich or
Aldrich’s father being an issue for a future job.546
The employee further stated when interviewed that, after the incident, he told
a fellow entry-level Front Office employee what happened in the taxi with
Aldrich and how Aldrich had “come on to” him.547 The employee stated that
his relationship with Aldrich was awkward for some time after the incident,
but that they continued to frequent bars along with other Front Office
employees.548 In the early fall of 2010, at Aldrich’s invitation, the employee
along with one other employee traveled to Houghton, Michigan to participate
in Aldrich hosting the Stanley Cup in Aldrich’s hometown.549
Aldrich stated that, while he remembered traveling with the Stanley Cup
around Chicago on June 10, 2010, and while he did not deny that an interaction
with this employee occurred, he did not recall taking a taxi home with a Front
Office intern, propositioning or grabbing an employee in a sexual manner
while in the taxi, or having a conversation with an employee about his sexual
orientation.550
On June 11, a parade was held in Chicago in honor of the Blackhawks’ Stanley
Cup win.551 John Doe recalled seeing Aldrich at the parade.552
2. Actions by Human Resources

On Monday, June 14, 2010, the Director of Human Resources was in her office
for her first full day since the Blackhawks won the Stanley Cup five days
earlier.553 According to the Director of Human Resources, McDonough called
her into his office and informed her for the first time of an issue involving

58
Aldrich that he stated he had learned about a few weeks earlier.554 This
conversation is described in detail above, in Section VII.B.5. At the end of the
meeting, the Director of Human Resources recalled, McDonough told her to
speak to Gary and MacIsaac.555
The Director of Human Resources next recalled contacting Gary.556 The
Director of Human Resources stated that Gary served as her conduit for
information and she never spoke directly to John Doe.557 Phone records reflect
at least one call between the Director of Human Resources and Gary on June
14, 2010.558 The Director of Human Resources did not recall what Gary told
her about the allegations other than unwanted sexual advances were made by
Aldrich.559 The Director of Human Resources stated that she believed that
Gary told her that Black Ace 1 was reluctant to talk about Aldrich.560 The
Director of Human Resources also stated that she believed Gary told John Doe
during the week of June 14 that the Blackhawks were addressing the issue
with Aldrich.561
The Director of Human Resources also recalled that she spoke to MacIsaac on
June 14, when he told her that Employee A told MacIsaac about an issue
regarding Aldrich.562 The Director of Human Resources recalled MacIsaac
explaining to her that Employee A came to his office prior to a home playoff
game and told MacIsaac that he should speak with two Black Aces.563 The
Director of Human Resources recalled MacIsaac stating that he had enlisted
Gary to talk to the Black Aces because of Gary’s relationship with the
players.564 The Director of Human Resources further recalled MacIsaac telling
her that Gary spoke to the players, including John Doe.565 The Director of
Human Resources recalled learning from Gary and MacIsaac that after Gary
spoke with the two players, he reported what he had learned to Bowman and
MacIsaac in the executive game suite at the United Center.566 The Director of
Human Resources recalled learning that, after Game 4 on May 23, Bowman,
MacIsaac, and Gary brought the issue to McDonough.567 When interviewed,
MacIsaac stated that he did not recall speaking with the Director of Human
Resources about Aldrich in June 2010.568
On June 15, the Director of Human Resources called Aldrich.569 Aldrich
recalled that he was in Houghton, Michigan at the time, and the Director of
Human Resources said that she needed to meet with him immediately.570

59
 3. Aldrich’s Separation from the Blackhawks Organization

On the morning of June 16, 2010, Aldrich met with the Director of Human
Resources571 and the Blackhawks’ outside counsel, whom the Director of
Human Resources had informed about the situation.n The Director of Human
Resources told Aldrich that there was an allegation against him by a player
regarding an unwanted sexual advance.572 The Director of Human Resources
recalled that either she or the outside counsel stated that they wanted to know
Aldrich’s side of the story.573 The Director of Human Resources could not
recall if John Doe’s name was referenced nor did she recall any other details of
what was said to Aldrich about the allegations.574 The outside counsel recalled
that Aldrich was told there was an allegation that Aldrich was hitting on John
Doe.575
The Director of Human Resources recalled that, upon hearing about the
allegation against him, Aldrich immediately shut down, became emotional,
and cried.576 The Director of Human Resources stated that Aldrich did not
admit or deny the allegation; the outside counsel stated that Aldrich denied
the allegation.577 The Director of Human Resources recalled telling Aldrich
that he had two options, which in her view were that Aldrich could take a leave
of absence while the Blackhawks conducted a formal investigation of the
allegation, or Aldrich could resign.578 The outside counsel recalled telling
Aldrich that the Blackhawks would need to conduct a full investigation, and if
the allegation was proven accurate, Aldrich would likely be discharged.579 The
Director of Human Resources next recalled that Aldrich responded that he did
not want an investigation and that he asked to resign.580
Aldrich recalled that the conversation with the Director of Human Resources
and the outside counsel was very short.581 He recalled the Director of Human
Resources explaining that there was an allegation of an inappropriate
relationship or conduct with a player.582 Aldrich stated that he immediately
knew that the allegation had to do with John Doe, as John Doe was the only

n The Blackhawks did not have an internal legal function at the time. The
Blackhawks’ outside counsel at the time was asked to be involved in certain
issues, including the separation of employees. The outside counsel who was
involved in Aldrich’s separation searched for but did not locate records
relevant to Aldrich or specifically to Aldrich’s separation.

60
player with whom Aldrich had a sexual encounter.583 Aldrich recalled that the
Director of Human Resources stated that Aldrich could take a leave of absence
while the Blackhawks investigated the allegation or Aldrich could sign a
separation agreement and leave the Blackhawks.584 Aldrich stated that he
believed his sexual orientation would be revealed if he chose the investigation
and so he chose to sign the agreement and leave the Blackhawks.585
The Director of Human Resources recalled sitting with Aldrich while the
outside counsel left the room to prepare the separation agreement.586 The
Director of Human Resources recalled that, while she sat with Aldrich, he was
emotional and sad.587 Aldrich recalled that the separation agreement was
already on the table when he arrived for the meeting and the outside counsel
walked through the agreement with him.588 The agreement included a
provision stating that Aldrich agreed not to contact or otherwise communicate
with any of the Blackhawks’ managers, coaches, or players, including
managers, coaches, and players employed by the Blackhawks’ American
Hockey League affiliate, “regarding any of the facts and matters relating in any
manner to the reasons for the separation of employment.”589
Aldrich recalled asking how long the Blackhawks would continue to pay
him.590 Aldrich was paid through August 31, 2010; received $20,622, less
taxes and withholding, in severance; and received a $15,000 playoff bonus.591
The Director of Human Resources and Aldrich both recalled that, during the
meeting, Aldrich requested to partake in the tradition of hosting the Stanley
Cup for a day.592 The Director of Human Resources recalled granting the
request during the meeting.593
The Director of Human Resources stated when interviewed that she could not
recall informing McDonough or MacIsaac about Aldrich’s departure, but
assumed she informed each of them and believed she personally informed
Quenneville.594 When interviewed, McDonough stated that he was not aware
of when or why Aldrich left the Blackhawks, and stated that he assumed it was
a coaching decision.595 MacIsaac stated when interviewed that he was not
involved in the decision regarding Aldrich’s separation and did not know
whether Aldrich was terminated or left on his own accord.596 Quenneville
stated that he was not involved in discussions about Aldrich’s separation and
he did not know the circumstances of Aldrich’s separation.597

61
Gary recalled that the Director of Human Resources told him that Aldrich was
no longer with the Blackhawks and that he could inform John Doe that Aldrich
was not allowed to see or communicate with any player or staff member.598
Gary recalled that when he called John Doe and told him the news about
Aldrich, John Doe seemed relieved and stated that he did not want to ever see
Aldrich again.599 John Doe also recalled a conversation with Gary about
Aldrich’s separation.600 John Doe recalled that Gary said during the
conversation that he believed John Doe.601 John Doe recalled Gary saying that
John Doe would never see Aldrich again, and that Aldrich would never contact
John Doe again.602 John Doe further recalled that Gary said that the
Blackhawks had given Aldrich the option to quit or the Blackhawks would
conduct an investigation and Aldrich chose to quit.603
***
The next section describes events that occurred after Aldrich’s separation
from the Blackhawks.
IX. Events that Occurred After Aldrich’s Separation from the
Blackhawks

A. Brad Aldrich

Soon after Aldrich’s separation, witnesses recalled seeing Aldrich during a

cleanout day in the locker room and hearing him tell players that he was
leaving the Blackhawks.604 One employee overheard Aldrich saying that he
was leaving because he was having a hard time with all of the travel.605 A
former player recalled Aldrich telling him in the hallway of the United Center
on cleanout day that he was leaving the Blackhawks to go home and to be
closer to family, and that he did not like to travel.606 On another occasion, a
former employee recalled Aldrich saying that he was leaving the Blackhawks
because he did not like to travel and the NHL “grind” was too hard on him.607
Despite his separation, Aldrich continued to participate in activities related to
the Blackhawks’ Stanley Cup win. He attended a Stanley Cup party at the home
of a Blackhawks trainer in Illinois, where he socialized with Blackhawks
trainers.608 In September 2010, Aldrich’s name was engraved on the Stanley
Cup along with the other coaches and players’ names.609 As noted above, the
Director of Human Resources agreed to allow Aldrich to host the Stanley Cup
for one day in his hometown of Houghton, Michigan.610 Two Blackhawks

62
employees, who said they were unaware of John Doe’s allegation regarding
Aldrich at the time they prepared the schedule of days for hosting the Cup,
worked with the Hockey Hall of Fame on the schedule.611 On September 14,
2010, Aldrich brought the Stanley Cup to his hometown of Houghton,
Michigan.612 Aldrich recalled that he received the Cup on a Monday night and
took the Cup to a local bar in Houghton.613 Aldrich stated that, the next
morning, he took the Cup to the local high school, around town, to dinner at
his family’s home, and finally to a party at the local ice rink.614 Aldrich recalled
that two Blackhawks employees traveled to Houghton, including the employee
who recalled the taxi incident on June 10.615 The two employees accompanied
Aldrich around Houghton with the Stanley Cup.616 A few weeks later, on
October 9, 2010, Aldrich attended a ceremony at the United Center, during
which the Stanley Cup banner was raised in the arena.617 On that day, Aldrich
recalled that he went to MacIsaac’s office and MacIsaac handed Aldrich his
Stanley Cup ring.618
In the months and years that followed, rumors about an incident or incidents
involving Aldrich and one or more players were prevalent in the Front Office
and among the players.619 We are not including every rumor that was
reported to us regarding Aldrich in this report. Certain rumors not only lacked
corroboration, but also lacked any plausibility. There were, however, some
rumors that were consistent with actual events. Blackhawks and IceHogs
players recalled hearing rumors about an incident involving Aldrich and John
Doe, or more generally an incident involving Aldrich and a player or players.
Specifically, several witnesses, including Front Office personnel and players,
recalled hearing rumors that Aldrich sent inappropriate text messages, was
involved in a “threesome” with a player, invited a player to come to his hotel
room, asked players to give him a “hand job,” and attempted to receive or
perform oral sex on a player.620
After leaving his employment with the Blackhawks, Aldrich went on to work
and volunteer at USA Hockey, the University of Notre Dame, Miami University
of Ohio, and Houghton High School.621 None of the witnesses we interviewed
recalled anyone at the Blackhawks providing a written or verbal reference for
Aldrich to his future employers. When interviewed, Aldrich stated that he did
not list any Blackhawks employees as references on job applications, nor did
he ask anyone from the Blackhawks to vouch for him or make any calls on his
behalf.622 USA Hockey reported to us that they identified no records reflecting

63
a reference provided for Aldrich by the Blackhawks.623 We gathered records
from Miami University regarding Aldrich’s employment and found no
evidence of references, whether written or oral, provided by the Blackhawks.
Miami University published an investigative report on September 24, 2021,
which stated that Aldrich did not provide references on his resume when he
applied to Miami, that the then-head coach of Miami University’s hockey team
received Aldrich’s name from the coach’s collegiate hockey connections, and
that the head coach and others spoke to the University of Notre Dame about
Aldrich and received favorable information.624 The Miami investigative report
does not describe any references provided by the Blackhawks.625 The
University of Notre Dame declined to share information or records with us,
other than to confirm Aldrich’s dates of employment at the university.
Houghton High School reported to us that they identified no records reflecting
a reference provided for Aldrich by the Blackhawks.626 The head hockey coach
at Houghton High School told us that Aldrich did not formally apply for
volunteer hockey coaching positions in 2010 and 2012.627 The head coach
explained that Aldrich’s uncle, who was the assistant coach in 2010, had told
the head coach that Aldrich was not working and asked if the team could help
Aldrich.628 In 2012, the team re-hired Aldrich as a volunteer based on his work
as a volunteer in 2010.629 The head coach said that he did not contact the
Blackhawks about Aldrich at any time.630
In March 2012, Aldrich visited the United Center for a Blackhawks game.631
After the game, he went downstairs to the talent hallway (which included a
door to the locker room) and was told by security to leave.632 Aldrich recalled
that the Director of Human Resources subsequently called him and told him
that he could not visit the talent hallway again.633 The Director of Human
Resources also recalled this event, as well as sending an email in which she
told MacIsaac that Aldrich attempted to contact players and obtain access to
the talent hallway, and that “both [were] unacceptable.”634
In September 2013, the Director of Human Resources was contacted by the
Houghton, Michigan Police Department.635 A detective stated that the police
were investigating Aldrich because Aldrich was suspected in a criminal sexual
assault.636 The Director of Human Resources recalled the detective telling her
that the police heard that there were “hang ups” with males affiliated with the
Blackhawks.637 The Director of Human Resources recalled telling the
Houghton detective that Aldrich had resigned, but that she could not provide

64
more details over the phone.638 The Director of Human Resources further
recalled that she told the detective that, if served with a subpoena, she would
cooperate.639 The Director of Human Resources stated that she did not recall
hearing from the detective again.640
In October 2013, Aldrich was arrested and charged in Houghton, Michigan
with third and fourth degree criminal sexual conduct involving a minor.641 In
December 2013, Aldrich pled guilty to fourth degree criminal sexual conduct
involving a minor.642 In 2014, Aldrich was sentenced to serve nine months in
jail and five years of probation.643
B. John Doe

After the 2010 Stanley Cup win, John Doe continued to be under contract with
the Blackhawks and played for the Rockford IceHogs. During the summer of
2010 and the 2010-2011 pre-season and regular season, John Doe had several
additional conversations with Jim Gary and recalled being subjected to rumors
and derogatory comments.644 When interviewed, Gary recalled that at the
September 2010 Blackhawks training camp, he told John Doe that he could
help find John Doe a therapist unaffiliated with the Blackhawks.645 Gary
recalled that John Doe did not seem interested in Gary’s suggestion.o, 646 John
Doe recalled that during the training camp, multiple players called John Doe
derogatory words and asked if John Doe missed “his boyfriend Brad.”647 None

o John Doe provided us with several 2009 and 2010 emails from Gary to John
Doe and other Blackhawks players, including, for example, Gary’s requests to
John Doe to schedule meetings. Certain of the emails from Gary to John Doe
included pictures of naked women, crude jokes of an explicit sexual nature,
and at least one email which had homophobic undertones. According to Gary,
he sometimes used what he regarded as juvenile sexual humor as part of an
effort to engage with the young male players in order to encourage them to
receive mental skills coaching and counseling from him. Gary stated that he
believed that using this type of humor would be effective in forming a
connection with John Doe.

65
of the players interviewed during our investigation admitted to making or
hearing about these or similar statements.
Gary recalled a counseling session with John Doe at Gary’s private office during
the 2010-2011 season.648 Gary recalled that John Doe did not seem interested
in speaking about Aldrich.649 Gary recalled that he told John Doe to contact the
Director of Human Resources if Aldrich tried to contact him.650
John Doe also recalled counseling sessions with Gary at Gary’s private office,
but had a different memory of the tone and content of the sessions.651 John
Doe recalled that the sessions were mandated by the Blackhawks and that he
spoke to Gary about his girlfriend and hockey.652 During the last session, John
Doe recalled that Gary said John Doe was partially at fault for what happened
between John Doe and Aldrich.653 John Doe recalled Gary saying that he put
himself in the situation and John Doe knew he should not have gone to
Aldrich’s apartment.654 John Doe recalled telling Gary that Gary was
protecting the Blackhawks and Aldrich.655 John Doe recalled that Gary was
upset by this comment, asked John Doe how he could think that, and told John
Doe that he had been doing his job for years.656
When John Doe learned that Aldrich was working with USA Hockey in late
2010, he called his confidant.p, 657 When interviewed, the confidant recalled
that John Doe was upset that Aldrich appeared to have a position with USA
Hockey.658 The confidant recalled John Doe stating that whether he was at
fault or not for what had occurred to him, John Doe did not want Aldrich “doing
this” to other people, in particular “kids,” and asked the confidant to help.659
The confidant recalled contacting Bowman, MacIsaac, or both, for a second
time in late 2010 or early 2011 regarding Aldrich’s work with USA Hockey.660
The confidant also recalled contacting Donald Fehr, who had recently been
named as Executive Director of the NHLPA.661 The confidant recalled telling
Fehr that he was apologetic that they were speaking for the first time under
unfortunate circumstances.662 The confidant recalled telling Fehr that he was
calling about an individual who was not a member of the NHLPA but who

pAldrich was working with the staff of one of the USA Hockey-affiliated teams
playing in the International Ice Hockey Foundation World Junior
Championship, which ran from December 26, 2010 through January 5, 2011.

66
experienced an incident with a coach who was now working with USA
Hockey.663 The confidant recalled that Fehr responded that he knew people at
USA Hockey, that the NHLPA would look into the situation, and that the NHLPA
could offer support.664 The confidant recalled that Fehr suggested that the
individual could speak to an NHLPA-affiliated therapist even though the
individual was not an NHLPA member.665 When interviewed, Fehr stated that
he did not recall a conversation with John Doe’s confidant, although he did not
deny that such a conversation occurred.666
The confidant further recalled that John Doe met with the NHLPA-affiliated
therapist.667 John Doe confirmed during his interview that his confidant
contacted the NHLPA in the fall of 2010 and put him in touch with the NHLPA-
affiliated therapist.668 We contacted the NHLPA-affiliated therapist, who
confirmed that he met or spoke with John Doe at least once, but stated that he
did not have any records related to John Doe or any recollection of the
meeting.669
The confidant also recalled when interviewed that he spoke to the professional
acquaintance of Black Ace 1.670 John Doe’s confidant recalled telling Black
Ace 1’s acquaintance in vague terms about John Doe and Aldrich.671 When
interviewed, Black Ace 1’s acquaintance also recalled having a conversation
with John Doe’s confidant, but he did not remember what John Doe’s confidant
said to him.672 Black Ace 1’s acquaintance further recalled knowing about a
text message from Aldrich suggesting that if John Doe or Black Ace 1 did not
spend more time with Aldrich, Aldrich would negatively impact the player’s
career.673 Black Ace 1’s acquaintance was not certain whether the text
message was sent to John Doe or Black Ace 1.674
As described in Section VI.G., Black Ace 1’s acquaintance contacted the NHL
Players’ Association in April 2011.675 In an email from Black Ace 1’s
acquaintance to the Executive Director of the NHLPA, Donald Fehr, the
acquaintance wrote, “I know you have spoken with [John Doe’s confidant]
regarding an incident with [John Doe] and a Chicago staff member during the
Stanley Cup Playoffs last year.”676 Fehr stated during an interview that he did
not recall a conversation with either John Doe’s confidant or Black Ace 1’s
acquaintance, although he did not deny that such conversations occurred.677
Regardless, this email corroborates that John Doe’s confidant contacted Fehr
regarding Aldrich and John Doe. Black Ace 1’s acquaintance also told us that
Black Ace 1 spoke with the same NHLPA-affiliated therapist with whom John

67
Doe spoke.678 The therapist, however, did not recall speaking with or have any
records related to Black Ace 1.679
X. Conclusion

In May 2010, a sexual encounter involving John Doe and Brad Aldrich occurred
at Aldrich’s apartment in Chicago. John Doe stated that the encounter was not
consensual and was a sexual assault. Brad Aldrich stated that the encounter
was consensual. In the days and weeks that followed, John Doe shared
information about the encounter with his confidant; the Blackhawks’ skating
coach (Paul Vincent); and the Blackhawks’ mental skills coach (Jim Gary), who
was dispatched by Al MacIsaac to speak to John Doe. Gary took information
he recalled receiving from John Doe to the senior leaders of the Blackhawks
organization.
There are multiple accounts of what occurred during the meeting of those
senior leaders at the United Center on May 23, 2010. Gary stated that he
shared with the senior leaders that Aldrich was pressuring John Doe for sex
and threatening to harm John Doe’s career if John Doe did not comply. Others
recall Gary’s comments as less stark—that Aldrich had tried to “get under the
sheets” with John Doe. At a minimum, the senior leaders, including then-
President John McDonough, were informed of alleged sexual harassment of a
player by a coach, including efforts by the coach to engage in unwelcome
sexual activity with that player. Several witnesses recalled or later told others
about a discussion that ensued during the meeting regarding whether the time
was right to address the allegations against Aldrich in light of the need to
protect team chemistry and avoid bad publicity during the ongoing playoffs.
What is clear is that, after being informed of Aldrich’s alleged sexual
harassment and misconduct with a player, no action was taken for three
weeks. One witness recalled that the decision on how to proceed was left in
McDonough’s hands and another witness recalled McDonough saying he
would speak to John Doe. McDonough did nothing to address the allegations
until June 14, when he reported the information to the Director of Human
Resources. While there was a lack of recollection as to whether anyone else
present in the meeting besides McDonough needed to or would take any
additional steps, nothing was done by the other senior leaders to address the
situation.

68
As a result, the Blackhawks’ own sexual harassment policy—which required
investigation of all reports of sexual harassment to be conducted “promptly
and thoroughly”—was violated. The failure to promptly and thoroughly
investigate the matter and the decision to take no action from May 23 to June
14 had consequences. During that period, Aldrich continued to work with and
travel with the team. Aldrich engaged in an unwanted sexual advance on a
Blackhawks intern—physically grabbing the intern in a sexual manner. And
Aldrich continued to participate in team activities and celebrations, in the
presence of John Doe.
Even after the allegations were finally reported to the Director of Human
Resources, still no investigation occurred, and Aldrich was permitted to resign
his position and to continue participating in Stanley Cup victory events.
***

69
 Appendix
Photo Credits: Chicago Blackhawks
June 9, 2010: Brad Aldrich with the Stanley Cup

70
June 9, 2010
From left: Paul Vincent; John Torchetti; Stephane Waite; Joel Quenneville;
Mike Haviland; Brad Aldrich.

71
June 11, 2010: Stanley Cup Parade in Chicago
From left: Al MacIsaac; John McDonough; Brad Aldrich; Paul Vincent.

72
June 13, 2010: The Stanley Cup at Wrigley Field in Chicago; Aldrich identified
with green circle.

73
 Endnotes

1 Complaint, John Doe v. Chicago Blackhawk Hockey Team, Inc., No. 2021 L 004728
(Cook Cnty. Cir. Ct. May 7, 2021) (“Doe (1) Complaint”).
2 Doe (1) Complaint, Count I, ¶¶ 1-12; Count II, ¶¶ 1-15; Count III, ¶¶ 1-9.
3First Amended Complaint, John Doe v. Chicago Blackhawk Hockey Team, Inc., No.
2021 L 004728 (Cook Cnty. Cir. Ct. July 22, 2021), Allegations Common to All Counts,
¶¶ 4-12; Count I (Negligent Hiring and Retention); Count II (Negligent Supervision);
Count III (Willful and Wanton Conduct); Count IV (Strict Liability - Illinois Human
Rights Act); Count V (Intentional Infliction of Emotional Distress) (“Doe (1) First
Amended Complaint”).
4Complaint, John Doe (2) v. Chicago Blackhawk Hockey Team, Inc., No. 2021 L 005435
(Cook Cnty. Cir. Ct., May 26, 2021) (“Doe (2) Complaint”).
5 Doe (2) Complaint, Count I, ¶¶ 1-11; Count II, ¶¶ 1-11.
6 Doe (2) Complaint, Counts I-II, ¶ 1.
7First Amended Complaint, John Doe (2) v. Chicago Blackhawk Hockey Team, Inc., No.
2021 L 005435 (Cook Cnty. Cir. Ct. July 22, 2021), Count I (Negligence); Count II
(Willful and Wanton Conduct).
8 C.A. Morgan III, Steven Southwick, George Steffian, Gary Hazlett, and Elizabeth
Loftus, Misinformation can influence memory for recently experienced, highly stressful
events, INTERNATIONAL JOURNAL OF LAW AND PSYCHIATRY, Jan.–Feb. 2013, at 2.
9Raymond S. Nickerson, Confirmation Bias: A Ubiquitous Phenomenon in Many Guises,
2 REVIEW OF GENERAL PSYCHOLOGY, no. 2, 1998, at 175.
10 Neal J. Roese and Kathleen D. Vohs, Hindsight Bias, 7 PERSPECTIVES ON PSYCHOLOGICAL

SCIENCE, no. 5, 2012, at 411.

11 Jenner & Block Interview of S. Bowman on August 12, 2021.
12 Jenner & Block Interview of S. Bowman on August 12, 2021.
13 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
14 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
15 Jenner & Block Interview of J. Gary on September 9, 2021.
16 Jenner & Block Interview of J. Gary on September 9, 2021.

74
17 Jenner & Block Interview of J. McDonough on August 10, 2021.
18 Jenner & Block Interview of J. McDonough on August 10, 2021.
19 Jenner & Block Interview of Witness on September 2, 2021; Jenner & Block
Interview of Witness on July 23, 2021; Jenner & Block Interview of Witness on July
19, 2021; Jenner & Block Interview of K. Cheveldayoff on August 5, 2021; Jenner &
Block Interview of Witness on July 13, 2021; Jenner & Block Interview of Witness on
July 19, 2021; Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block
Interview of Witness on July 26, 2021; Jenner & Block Interview of J. Quenneville on
July 20, 2021; Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block
Interview of Witness on July 16, 2021; Jenner & Block Interview of A. MacIsaac on
August 10, 2021; Jenner & Block Interview of Witness on July 23, 2021; Jenner & Block
Interview of Witness on July 28, 2021; Jenner & Block Interview of Witness on August
3, 2021; Jenner & Block Interview of Witness on August 9, 2021; Jenner & Block
Interview of Witness on September 22, 2021.
20 Jenner & Block Interview of J. McDonough on August 10, 2021.
21 Jenner & Block Interview of J. McDonough on August 10, 2021.
22 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 5(b)(i)-(iii); Jenner & Block Interview of Director of Human Resources on July 1,
2021.
23 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 5(b)(i)-(iii).
24 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 6(y).
25 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 6(y).
26 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 6(y).
27 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 6(y).
28 Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,
¶ 6(y).
Chicago Blackhawks Hockey Team Rules, 2009-2010; October 1, 2021 Email from
29

Witness to Jenner & Block.

75
 Chicago Blackhawks Hockey Team Rules, 2009-2010; October 1, 2021 Email from
30

Witness to Jenner & Block.

31 See, e.g., Jenner & Block Interview of Witness on September 19, 2021; Jenner &
Block Interview of J. McDonough on August 10, 2021; Jenner & Block Interview of S.
Bowman on August 12, 2021; Jenner & Block Interview of Witness on August 16,
2021; Jenner & Block Interview of Witness on July 21, 2021; Jenner & Block Interview
of Witness on August 10, 2021; Jenner & Block Interview of Witness on August 18,
2021; Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview
of Witness on July 8, 2021; Jenner & Block Interview of Witness on July 9, 2021; Jenner
& Block Interview of Witness on July 12, 2021; Jenner & Block Interview of Witness
on July 13, 2021; Jenner & Block Interview of Witness on July 14, 2021; Jenner & Block
Interview of Witness on July 16, 2021; Jenner & Block Interview of Witness on July
16, 2021; Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block
Interview of Witness on July 22, 2021; Jenner & Block Interview of Witness on July
22, 2021; Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block
Interview of Witness on July 23, 2021; Jenner & Block Interview of Witness on July
28, 2021; Jenner & Block Interview of Witness on August 6, 2021; Jenner & Block
Interview of Witness on July 22, 2021; Jenner & Block Interview of Witness on July
20, 2021; Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block
Interview of Witness on July 20, 2021; Jenner & Block Interview of Witness on July
20, 2021; Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block
Interview of Witness on August 9, 2021; Jenner & Block Interview of Witness on
August 10, 2021; Jenner & Block Interview of Witness on August 25, 2021; Jenner &
Block Interview of Witness on July 8, 2021; Jenner & Block Interview of Witness on
July 15, 2021; Jenner & Block Interview of Witness on July 19, 2021; Jenner & Block
Interview of Witness on July 22, 2021; Jenner & Block Interview of Witness on July
26, 2021; Jenner & Block Interview of Witness on July 28, 2021; Jenner & Block
Interview of Witness on July 12, 2021; Jenner & Block Interview of Witness on July
20, 2021; Jenner & Block Interview of Witness on July 16, 2021.
32Blackhawks 2008 Video Coach Job Description; Jenner & Block Interview of B.
Aldrich on August 21, 2021.
33 Jenner & Block Interview of Witness on July 13, 2021.
34 Jenner & Block Interview of B. Aldrich on August 21, 2021; Resume of B. Aldrich.
35 Jenner & Block Interview of D. Tallon on August 24, 2021.
36 Jenner & Block Interview of D. Tallon on August 24, 2021.
37 Jenner & Block Interview of A. MacIsaac on August 10, 2021; Jenner & Block
Interview of P. Vincent on August 7, 2021.

76
38 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
39 Jenner & Block Interview of B. Aldrich on August 21, 2021.
40 Jenner & Block Interview of B. Aldrich on August 21, 2021.
41 Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block
Interview of S. Bowman on September 24, 2021.
42 Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block
Interview of S. Bowman on September 24, 2021.
43 Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block
Interview of S. Bowman on September 24, 2021.
44 Jenner & Block Interview of B. Aldrich on August 21, 2021.
45 Jenner & Block Interview of B. Aldrich on August 21, 2021.
46 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
47 Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview of
J. McDonough on August 10, 2021; Jenner & Block Interview of J. Blunk on July 26,
2021. See also Jenner & Block Interview of B. Aldrich on August 21, 2021.
48 Jenner & Block Interview of B. Aldrich on August 21, 2021.
49July 25, 2008 Employment Agreement of B. Aldrich; June 16, 2010 Separation
Agreement of B. Aldrich.
50 Jenner & Block Interview of B. Aldrich on August 21, 2021.
51 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block Interview

of Witness on July 6, 2021; Jenner & Block Interview of Witness on July 20, 2021;
Jenner & Block Interview of Witness on July 30, 2021; Jenner & Block Interview of
John Doe on September 20, 2021; Jenner & Block Interview of Witness on July 21,
2021.
52 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block Interview

of Witness on July 6, 2021; Jenner & Block Interview of Witness on July 20, 2021;
Jenner & Block Interview of Witness on July 30, 2021.
53 Jenner & Block Interview of B. Aldrich on August 21, 2021.
54 January 2, 2009 Performance Evaluation of B. Aldrich.
55 January 2, 2009 Performance Evaluation of B. Aldrich.

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56 June 3, 2009 Performance Evaluation of B. Aldrich
57 June 29, 2010 Performance Evaluation of B. Aldrich.
58 Jenner & Block Interview of J. Quenneville on September 27, 2021.
59 Jenner & Block Interview of J. Quenneville on September 27, 2021.
60Jenner & Block Interview of Witness on July 13, 2021; Jenner & Block Interview of
Witness on July 14, 2021; Jenner & Block Interview of Witness on July 16, 2021;
Jenner & Block Interview of Witness on July 16, 2021; Jenner & Block Interview of
Witness on July 19, 2021; Jenner & Block Interview of Witness on July 19, 2021;
Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block Interview of
Witness on July 21, 2021; Jenner & Block Interview of Witness on July 22, 2021;
Jenner & Block Interview of Witness on July 21, 2021; Jenner & Block Interview of
Witness on July 22, 2021; Jenner & Block Interview of Witness on July 26, 2021;
Jenner & Block Interview of Witness on July 28, 2021; Jenner & Block Interview of
Witness on August 3, 2021; Jenner & Block Interview of Witness on August 9, 2021;
Jenner & Block Interview of Witness on August 10, 2021; Jenner & Block Interview of
Witness on August 12, 2021; Jenner & Block Interview of Witness on August 11, 2021;
Jenner & Block Interview of Witness on July 23, 2021.
Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block Interview of
61

Witness on July 12, 2021; Jenner & Block Interview of Witness on July 26, 2021.
62 Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 8, 2021; Jenner & Block Interview of Witness on July 12, 2021; Jenner
& Block Interview of Witness on July 21, 2021; Jenner & Block Interview of Witness
on July 21, 2021; Jenner & Block Interview of Witness on July 21, 2021; Jenner & Block
Interview of Witness on July 23, 2021; Jenner & Block Interview of Witness on July
28, 2021; Jenner & Block Interview of Witness on August 12, 2021; Jenner & Block
Interview of Witness on August 26, 2021; Jenner & Block Interview of Witness on July
6, 2021.
63Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of J. Quenneville on September 27, 2021; Jenner & Block Interview of Witness on July
8, 2021; Jenner & Block Interview of Witness on July 13, 2021; Jenner & Block
Interview of Witness on July 20, 2021; Jenner & Block Interview of Witness on July
21, 2021; Jenner & Block Interview of Witness on July 30, 2021; Jenner & Block
Interview of Witness on July 6, 2021.
Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
64

Witness on July 9, 2021.

78
 Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
65

Witness on July 6, 2021; Jenner & Block Interview of Witness on July 16, 2021.
66 Jenner & Block Interview of Witness on July 29, 2021.
Jenner & Block Interview of Witness on July 15, 2021; Jenner & Block Interview of
67

Witness on July 22, 2021.

68 Jenner & Block Interview of Witness on August 9, 2021.
Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block Interview of
69

Witness on July 13, 2021.

70 Jenner & Block Interview of Witness on July 13, 2021.
71Jenner & Block Interview of Witness on July 14, 2021; Jenner & Block Interview of
Witness on July 23, 2021; Jenner & Block Interview of Witness on July 6, 2021; Jenner
& Block Interview of Witness on July 8, 2021; Jenner & Block Interview of Witness on
July 14, 2021; Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block
Interview of Witness on July 28, 2021.
72 Jenner & Block Interview of Witness on July 14, 2021; Jenner & Block Interview of
A. MacIsaac on August 10, 2021.
73 Jenner & Block Interview of Witness on July 6, 2021.
74Chris Kuc, Blackhawks beat Flyers to win Stanley Cup, CHICAGO TRIBUNE (April 4,
2010), https://www.chicagotribune.com/sports/blackhawks/ct-xpm-2010-04-04-
chi-100404-chicago-blackhawkss-flames-story.html.
75 2009-10 Blackhawks Schedule and Results, Hockey Reference, https://www.hockey-

reference.com/teams/CHI/2010_games.html (last visited Oct. 10, 2021) (“2010

Blackhawks Schedule”).
76 Blackhawks Recall Eight From Rockford, Chicago Blackhawks (April 28, 2010),
https://www.nhl.com/blackhawks/news/blackhawks-recall-eight-from-
rockford/c-527341; 2010 Black Aces Per Diem In Chicago.
77 Habs force Caps showdown, Bruins and Chicago win, REUTERS (April 26, 2010),
https://www.reuters.com/article/us-nhl-playoffs-monday/habs-force-caps-
showdown-bruins-and-chicago-win-idUSTRE63Q0HO20100427; Ammad Omar,
Blackhawks Win; On To Conference Finals, WBEZ CHICAGO (May 11, 2010),
https://www.wbez.org/stories/blackhawks-win-on-to-conference-
finals/b419a693-14a6-46f7-8120-fe60938402c3; Blackhawks finish off Sharks,
advance to Stanley Cup, N.Y. POST (May 23, 2010),

79
https://nypost.com/2010/05/23/blackhawks-finish-off-sharks-advance-to-stanley-
cup/.
78 Chris Kuc, Blackhawks beat Flyers to win Stanley Cup, CHICAGO TRIBUNE (June 9,
2010), https://www.chicagotribune.com/sports/blackhawks/ct-spt-0610-
blackhawks-flyers-chicago20100609-story.html.
79Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 6, 2021; Jenner & Block Interview of Witness on July 8, 2010; Jenner
& Block Interview of J. Quenneville on July 20, 2021.
80Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 6, 2021; Jenner & Block Interview of Witness on July 8, 2021; Jenner
& Block Interview of J. Quenneville on July 20, 2021.
81Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 6, 2021; Jenner & Block Interview of Witness on July 8, 2021; Jenner
& Block Interview of J. Quenneville on July 20, 2021; Jenner & Block Interview of
Witness on July 23, 2021.
82Jenner & Block Interview of Witness on July 9, 2021; Jenner & Block Interview of
Witness on July 21, 2021; Jenner & Block Interview of Witness on August 3, 2021;
Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 8, 2021; Jenner & Block Interview of Witness on July 8, 2021; Jenner
& Block Interview of Witness on July 23, 2021.
Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
83

Witness on July 8, 2021; Jenner & Block Interview of Witness on July 23, 2021.
2010 Playoffs - Round 2 - Vancouver Manifest; 2010 Playoffs - Round 3 - San Jose
84

Manifest; Rockford Staff - Black Aces Coverage.

85Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
John Doe on September 20, 2021; Jenner & Block Interview of Witness on September
14, 2021; Jenner & Block Interview of Witness on August 16, 2021.
86 Jenner & Block Interview of B. Aldrich on August 21, 2021.
87Jenner & Block Interview of Witness on July 9, 2021; Jenner & Block Interview of
Witness on July 13, 2021; Jenner & Block Interview of Witness on July 14, 2021;
Jenner & Block Interview of Witness on September 10, 2021.
88 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block Interview

of Witness on July 29, 2021.

89 Jenner & Block Interview of Witness on July 14, 2021.

80
90 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block Interview

of Black Ace 1 on August 24, 2021.

91 Chicago Blackhawks Verizon Phone Records (May-June 2010).
92 Jenner & Block Interview of John Doe on September 20, 2021.
Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
93

Witness on July 6, 2021.

94 Jenner & Block Interview of Witness on July 16, 2021.
95 Jenner & Block Interview of Witness on July 16, 2021.
96 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
97 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
98 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
99Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block Interview of
Witness on July 30, 2021; Jenner & Block Interview of Witness on August 12, 2021;
Jenner & Block Interview of Witness on August 19, 2021; Jenner & Block Interview of
Witness on August 20, 2021; Jenner & Block Interview of Witness on August 30, 2021.
100 2010 Blackhawks Schedule.
101 Jenner & Block Interview of John Doe on September 20, 2021.
102 Jenner & Block Interview of John Doe on September 20, 2021.
103 Jenner & Block Interview of John Doe on September 20, 2021.
104 Jenner & Block Interview of John Doe on September 20, 2021.
105 Jenner & Block Interview of Witness on August 16, 2021.
106 Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of John Doe on September 20, 2021.
107 2010 Blackhawks Schedule.
108 Jenner & Block Interview of John Doe on September 20, 2021.
109 Jenner & Block Interview of John Doe on September 20, 2021.
110 Jenner & Block Interview of John Doe on September 20, 2021.
111 Jenner & Block Interview of John Doe on September 20, 2021.

81
112 Jenner & Block Interview of John Doe on September 20, 2021.
113 Jenner & Block Interview of John Doe on September 20, 2021.
114 Jenner & Block Interview of John Doe on September 20, 2021.
115 Blackhawks 2010 Playoffs Travel Records.
116 Jenner & Block Interview of B. Aldrich on August 21, 2021.
117 Jenner & Block Interview of John Doe on September 20, 2021.
118 Jenner & Block Interview of John Doe on September 20, 2021.
119 Blackhawks 2010 Playoffs Travel Records.
120Blackhawks 2010 Playoffs Travel Records; see, e.g., Jenner & Block Interview of B.
Aldrich on August 21, 2021; Jenner & Block Interview of Witness on July 14, 2021.
121 Jenner & Block Interview of John Doe on September 20, 2021; Email from Witness
to John Doe, et al., FW: e-tkts issued for 7 players to San Jose (May 11, 2010).
122 Jenner & Block Interview of John Doe on September 20, 2021.
123 October 5, 2021 Email from John Doe.
124 Jenner & Block Interview of John Doe on September 20, 2021.
125 Jenner & Block Interview of John Doe on September 20, 2021.
126 Jenner & Block Interview of John Doe on September 20, 2021.
127 Jenner & Block Interview of John Doe on September 20, 2021.
128 Jenner & Block Interview of John Doe on September 20, 2021.
129 Jenner & Block Interview of John Doe on September 20, 2021.
130 Jenner & Block Interview of John Doe on September 20, 2021.
131 Jenner & Block Interview of John Doe on September 20, 2021.
132 Jenner & Block Interview of John Doe on September 20, 2021.
133 Jenner & Block Interview of John Doe on September 20, 2021.
134 Jenner & Block Interview of John Doe on September 20, 2021.
135 Jenner & Block Interview of John Doe on September 20, 2021.
136 Jenner & Block Interview of John Doe on September 20, 2021.

82
137 Jenner & Block Interview of John Doe on September 20, 2021.
138 Jenner & Block Interview of John Doe on September 20, 2021.
139 Jenner & Block Interview of John Doe on September 20, 2021.
140 Jenner & Block Interview of John Doe on September 20, 2021.
141 Jenner & Block Interview of John Doe on September 20, 2021.
142 Jenner & Block Interview of John Doe on September 20, 2021.
143 Jenner & Block Interview of John Doe on September 20, 2021.
144 Jenner & Block Interview of John Doe on September 20, 2021.
145 Jenner & Block Interview of John Doe on September 20, 2021.
146 Jenner & Block Interview of John Doe on September 20, 2021.
147 Jenner & Block Interview of John Doe on September 20, 2021.
148 Jenner & Block Interview of John Doe on September 20, 2021.
149 Jenner & Block Interview of John Doe on September 20, 2021.
150 Jenner & Block Interview of John Doe on September 20, 2021.
151 Jenner & Block Interview of John Doe on September 20, 2021.
152 Jenner & Block Interview of John Doe on September 20, 2021.
153 Jenner & Block Interview of John Doe on September 20, 2021.
154 Jenner & Block Interview of John Doe on September 20, 2021.
155 Jenner & Block Interview of John Doe on September 20, 2021.
156 Jenner & Block Interview of John Doe on September 20, 2021.
157 Jenner & Block Interview of John Doe on September 20, 2021.
158 Jenner & Block Interview of John Doe on September 20, 2021.
159 Jenner & Block Interview of John Doe on September 20, 2021.
160 Jenner & Block Interview of John Doe on September 20, 2021.
161 Jenner & Block Interview of John Doe on September 20, 2021.
162 Jenner & Block Interview of John Doe on September 20, 2021.

83
163 Jenner & Block Interview of John Doe on September 20, 2021.
164 Jenner & Block Interview of John Doe on September 20, 2021.
165 Jenner & Block Interview of John Doe on September 20, 2021.
166 Jenner & Block Interview of John Doe on September 20, 2021.
167 Jenner & Block Interview of John Doe on September 20, 2021.
168 Jenner & Block Interview of John Doe on September 20, 2021.
169 Jenner & Block Interview of John Doe on September 20, 2021.
170 Jenner & Block Interview of John Doe on September 20, 2021.
171 Jenner & Block Interview of Witness on August 16, 2021.
172 2010 Blackhawks Schedule.
173 Jenner & Block Interview of Witness on August 16, 2021.
174 Jenner & Block Interview of Witness on August 16, 2021.
175 Jenner & Block Interview of Witness on August 16, 2021.
176Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on August 11, 2021.
177 Jenner & Block Interview of Witness on August 16, 2021.
178 Jenner & Block Interview of Witness on August 16, 2021.
179 Jenner & Block Interview of Witness on August 16, 2021.
180 Jenner & Block Interview of Witness on August 16, 2021.
181Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on August 11, 2021.
182 Jenner & Block Interview of Witness on August 16, 2021.
183 Jenner & Block Interview of Witness on August 16, 2021.
184 Jenner & Block Interview of Witness on August 16, 2021.
185 Jenner & Block Interview of Witness on August 16, 2021.
186 Jenner & Block Interview of Witness on August 16, 2021.
187 Jenner & Block Interview of Witness on August 16, 2021.

84
188 Jenner & Block Interview of Witness on August 16, 2021.
189 Jenner & Block Interview of Witness on August 16, 2021.
190 Jenner & Block Interview of Witness on August 16, 2021.
191 Jenner & Block Interview of Witness on August 16, 2021.
192 Jenner & Block Interview of Witness on August 16, 2021.
193 Jenner & Block Interview of Witness on August 16, 2021.
194 Jenner & Block Interview of Witness on August 16, 2021.
195 Jenner & Block Interview of Witness on August 16, 2021.
196Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on August 11, 2021.
197Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on August 11, 2021.
198 Jenner & Block Interview of Witness on August 16, 2021.
199Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
200Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
201Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
202 Jenner & Block Interview of B. Aldrich on August 21, 2021.
203Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
204 Jenner & Block Interview of B. Aldrich on August 21, 2021.
205Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
206 Jenner & Block Interview of B. Aldrich on August 21, 2021.
207Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
208 Jenner & Block Interview of B. Aldrich on August 21, 2021.

85
209 Jenner & Block Interview of B. Aldrich on August 21, 2021.
210 Jenner & Block Interview of B. Aldrich on August 21, 2021.
211 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block
Interview of Witness on August 26, 2021.
212 Jenner & Block Interview of B. Aldrich on August 21, 2021.
213 Jenner & Block Interview of B. Aldrich on August 21, 2021.
214 Jenner & Block Interview of B. Aldrich on August 21, 2021.
215 Jenner & Block Interview of B. Aldrich on August 21, 2021.
216 Jenner & Block Interview of B. Aldrich on August 21, 2021.
217Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
218 Jenner & Block Interview of B. Aldrich on August 21, 2021.
219 Jenner & Block Interview of B. Aldrich on August 21, 2021.
220 Jenner & Block Interview of B. Aldrich on August 21, 2021.
221 Jenner & Block Interview of B. Aldrich on August 21, 2021.
222 Jenner & Block Interview of B. Aldrich on August 21, 2021.
223 Jenner & Block Interview of B. Aldrich on August 21, 2021.
224 Jenner & Block Interview of B. Aldrich on August 21, 2021.
225 Jenner & Block Interview of B. Aldrich on August 21, 2021.
226 Jenner & Block Interview of B. Aldrich on August 21, 2021.
227Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Black Ace 1 on August 24, 2021.
228 Jenner & Block Interview of B. Aldrich on August 21, 2021.
229 Jenner & Block Interview of Witness on August 26, 2021.
230 Jenner & Block Interview of Witness on August 26, 2021.
231 Jenner & Block Interview of Witness on August 26, 2021.
232 Jenner & Block Interview of Witness on August 26, 2021.

86
233 Jenner & Block Interview of Witness on August 26, 2021.
234 Jenner & Block Interview of Witness on August 26, 2021.
235 Jenner & Block Interview of Witness on August 26, 2021.
236 Jenner & Block Interview of Witness on August 26, 2021.
237 Jenner & Block Interview of Witness on August 26, 2021.
238 Jenner & Block Interview of Witness on August 26, 2021.
239 Jenner & Block Interview of Witness on August 26, 2021.
240 Jenner & Block Interview of Witness on August 26, 2021.
241 Jenner & Block Interview of Witness on August 26, 2021.
242 Jenner & Block Interview of Witness on August 26, 2021.
243 Jenner & Block Interview of Witness on August 26, 2021.
244 Jenner & Block Interview of Witness on August 26, 2021.
245 Jenner & Block Interview of Witness on August 26, 2021.
246 Jenner & Block Interview of Witness on August 26, 2021.
247 Jenner & Block Interview of Witness on August 26, 2021.
248 Jenner & Block Interview of Witness on August 26, 2021.
249 Jenner & Block Interview of Witness on August 26, 2021.
250 Jenner & Block Interview of Witness on August 26, 2021.
251 Jenner & Block Interview of Witness on August 26, 2021.
252 Jenner & Block Interview of John Doe on September 20, 2021.
253 Jenner & Block Interview of John Doe on September 20, 2021.
254 Jenner & Block Interview of John Doe on September 20, 2021.
255 Jenner & Block Interview of John Doe on September 20, 2021.
256 Jenner & Block Interview of John Doe on September 20, 2021.
257 Jenner & Block Interview of John Doe on September 20, 2021.
258 Jenner & Block Interview of John Doe on September 20, 2021.

87
259 Jenner & Block Interview of John Doe on September 20, 2021.
260 Jenner & Block Interview of John Doe on September 20, 2021.
261 Jenner & Block Interview of John Doe on September 20, 2021.
262 Jenner & Block Interview of John Doe on September 20, 2021.
263 Jenner & Block Interview of John Doe on September 20, 2021.
264 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
265 July 14, 2021 Email from Black Ace 1 to Jenner & Block.
266 Jenner & Block Interview of B. Aldrich on August 21, 2021.
267 Chicago Blackhawks Verizon Records (May 2010).
268 Chicago Blackhawks Verizon Records (May 2010).
269 Jenner & Block Interview of Witness on July 16, 2021.
270 Jenner & Block Interview of Witness on July 16, 2021.
271 Jenner & Block Interview of Witness on July 16, 2021.
272 Jenner & Block Interview of Witness on July 13, 2021.
273 Jenner & Block Interview of Witness on July 13, 2021.
274 Jenner & Block Interview of Witness on July 13, 2021.
275 Jenner & Block Interview of Witness on July 13, 2021.
276 Jenner & Block Interview of Witness on July 13, 2021.
277 Jenner & Block Interview of Witness on July 13, 2021.
278 Jenner & Block Interview of Witness on August 19, 2021.
279 Jenner & Block Interview of Witness on August 19, 2021.
280 See generally Doe (1) First Amended Complaint.
281 Jenner & Block Interview of B. Sopel on August 12, 2021; Jenner & Block Interview
of Witness on July 30, 2021; Jenner & Block Interview of Witness on July 16, 2021;
Jenner & Block Interview of Witness on July 13, 2021; Jenner & Block Interview of
Witness on August 19, 2021; Jenner & Block Interview of Witness on August 16, 2021;
Jenner & Block Interview of Witness on August 12, 2021; Jenner & Block Interview of
S. Bowman on August 12, 2021; Jenner & Block Interview of Witness on July 20, 2021;

88
Jenner & Block Interview of Witness on July 23, 2021; Jenner & Block Interview of
Witness on July 2, 2021; Jenner & Block Interview of Witness on July 9, 2021; Jenner
& Block Interview of Witness on July 13, 2021; Jenner & Block Interview of Witness
on September 10, 2021.
282 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
283 Jenner & Block Interview of B. Aldrich on August 21, 2021.
284 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
285 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
286 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
287 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
288 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
289 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
290 Jenner & Block Interview of B. Aldrich on August 21, 2021.
291 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
292 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
293 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
294 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
295 Jenner & Block Interview of Witness on July 8, 2021.
296 Jenner & Block Interview of Witness on July 8, 2021.
297 Jenner & Block Interview of Witness on July 8, 2021.
298 Jenner & Block Interview of Witness on July 8, 2021.
299 Jenner & Block Interview of Witness on July 8, 2021.
300 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
301 Jenner & Block Interview of Witness on September 30, 2021.
302Email from Witness to D. Fehr re: Discussion (April 18, 2011); Jenner & Block
Interview of Witness on September 30, 2021.
303 Jenner & Block Interview of Witness on September 30, 2021.
304 Jenner & Block Interview of Witness on September 30, 2021.

89
305 Jenner & Block Interview of Witness on September 30, 2021.
306 Jenner & Block Interview of Witness on September 30, 2021.
307 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
308 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
309 Player Evaluations 2010-2011 Season.
310 Jenner & Block Interview of Witness on August 12, 2021.
311 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
312 Blackhawks 2010 Playoffs Travel Records.
313Jenner & Block Interview of Witness on July 14, 2021; Jenner & Block Interview of
Witness on August 19, 2021; Email from Witness to John Doe, et al. FW: e-tkts issued
for 7 players to San Jose (May 11, 2010).
314 Blackhawks 2010 Playoffs Travel Records.
315 Jenner & Block Interview of John Doe on September 20, 2021.
316 Jenner & Block Interview of Witness on August 16, 2021.
317 Jenner & Block Interview of John Doe on September 20, 2021.
318 Jenner & Block Interview of John Doe on September 20, 2021.
319 Jenner & Block Interview of John Doe on September 20, 2021.
320 Jenner & Block Interview of John Doe on September 20, 2021.
321 2010 Blackhawks Schedule.
322 2010 Blackhawks Schedule.
323 Jenner & Block Interview of Witness on July 8, 2021.
324 Jenner & Block Interview of Witness on July 8, 2021.
325 Jenner & Block Interview of Witness on July 8, 2021.
326 Jenner & Block Interview of Witness on July 8, 2021.
327Jenner & Block Interview of Black Ace 1 on August 24, 2021; Jenner & Block
Interview of John Doe on September 20, 2021.
328 Jenner & Block Interview of B. Aldrich on August 21, 2021.

90
329 Jenner & Block Interview of Witness on July 8, 2021.
330 Jenner & Block Interview of Witness on July 8, 2021.
331 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
332 2010 Blackhawks Schedule.
333 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
334 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
335 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
336 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
337 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
338 Jenner & Block Interview of A. MacIsaac on September 24, 2021.
339 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
340 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
341 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
342 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
343 Jenner & Block Interview of J. Gary on September 9, 2021.
344 Jenner & Block Interview of J. Gary on September 9, 2021.
345 Jenner & Block Interview of J. Gary on September 9, 2021.
346 Jenner & Block Interview of John Doe on September 20, 2021.
347 Jenner & Block Interview of John Doe on September 20, 2021.
348 Jenner & Block Interview of John Doe on September 20, 2021.
349 Jenner & Block Interview of John Doe on September 20, 2021.
350 Jenner & Block Interview of John Doe on September 20, 2021.
351 Jenner & Block Interview of J. Gary on September 9, 2021.
352 Jenner & Block Interview of J. Gary on September 9, 2021.
353 Jenner & Block Interview of J. Gary on September 9, 2021.
354 Jenner & Block Interview of J. Gary on September 9, 2021.

91
355 Jenner & Block Interview of John Doe on September 20, 2021.
356 Jenner & Block Interview of John Doe on September 20, 2021.
357 Jenner & Block Interview of John Doe on September 20, 2021.
358 Jenner & Block Interview of John Doe on September 20, 2021.
359 Jenner & Block Interview of John Doe on September 20, 2021.
360 Jenner & Block Interview of J. Gary on September 9, 2021.
361 Jenner & Block Interview of J. Gary on September 9, 2021.
362 Jenner & Block Interview of J. Gary on September 9, 2021.
363 Jenner & Block Interview of J. Gary on September 9, 2021.
364 Jenner & Block Interview of J. Gary on September 9, 2021.
365 Jenner & Block Interview of J. Gary on September 9, 2021.
366 Jenner & Block Interview of J. Gary on September 9, 2021.
367 Jenner & Block Interview of J. Gary on September 9, 2021.
368 Jenner & Block Interview of J. Gary on September 9, 2021.
369 Jenner & Block Interview of J. Gary on September 9, 2021.
370 Jenner & Block Interview of J. Gary on September 9, 2021.
371 Jenner & Block Interview of J. Gary on September 9, 2021.
372 Jenner & Block Interview of J. Gary on September 9, 2021.
373 Jenner & Block Interview of J. Gary on September 9, 2021.
374 Jenner & Block Interview of J. Gary on September 9, 2021.
375 Jenner & Block Interview of J. Gary on September 9, 2021.
376 Jenner & Block Interview of J. Gary on September 9, 2021.
377 Jenner & Block Interview of J. Gary on September 9, 2021.
378 Jenner & Block Interview of Black Ace 1 on August 24, 2021.
379 Jenner & Block Interview of John Doe on September 20, 2021.
380 Jenner & Block Interview of John Doe on September 20, 2021.

92
381 Jenner & Block Interview of John Doe on September 20, 2021.
382 Jenner & Block Interview of John Doe on September 20, 2021.
383 Jenner & Block Interview of J. Gary on September 9, 2021.
384 Jenner & Block Interview of J. Gary on September 9, 2021.
385 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
386 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
387 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
388 Jenner & Block Interview of S. Bowman on August 12, 2021.
389 Jenner & Block Interview of S. Bowman on August 12, 2021.
390 Jenner & Block Interview of S. Bowman on August 12, 2021.
391 Jenner & Block Interview of S. Bowman on August 12, 2021.
392Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block
Interview of K. Cheveldayoff on August 5, 2021; Jenner & Block Interview of J.
McDonough on August 10, 2021.
393 Jenner & Block Interview of S. Bowman on August 12, 2021.
394 Jenner & Block Interview of S. Bowman on August 12, 2021.
395 Jenner & Block Interview of J. Quenneville on July 20, 2021.
396 Jenner & Block Interview of J. Gary on September 9, 2021.
397 Jenner & Block Interview of J. Gary on September 9, 2021.
398 Jenner & Block Interview of J. Gary on September 9, 2021.
399 Jenner & Block Interview of J. Gary on September 9, 2021.
400 Jenner & Block Interview of J. Gary on September 9, 2021.
401 Jenner & Block Interview of J. Gary on September 9, 2021.
402 Jenner & Block Interview of J. Gary on September 9, 2021.
403 Jenner & Block Interview of J. Gary on September 9, 2021.
404 Jenner & Block Interview of J. Gary on September 9, 2021.
405 Jenner & Block Interview of Director of Human Resources on October 11, 2021.

93
406 Jenner & Block Interview of S. Bowman on August 12, 2021.
407 Jenner & Block Interview of S. Bowman on September 24, 2021.
408 Jenner & Block Interview of S. Bowman on August 12, 2021.
409 Jenner & Block Interview of S. Bowman on August 12, 2021.
410 Jenner & Block Interview of S. Bowman on August 12, 2021.
411 Jenner & Block Interview of S. Bowman on August 12, 2021.
412 Jenner & Block Interview of S. Bowman on August 12, 2021.
413 Jenner & Block Interview of S. Bowman on September 24, 2021.
414 Jenner & Block Interview of S. Bowman on August 12, 2021.
415 Jenner & Block Interview of S. Bowman on August 12, 2021.
416 Jenner & Block Interview of A. MacIsaac on September 24, 2021.
417 Jenner & Block Interview of A. MacIsaac on September 24, 2021.
418Jenner & Block Interview of A. MacIsaac on August 10, 2021; Jenner & Block
Interview of A. MacIsaac on September 24, 2021.
419 Jenner & Block Interview of Witness on August 3, 2021.
420 Jenner & Block Interview of Witness on August 3, 2021.
421 Jenner & Block Interview of Witness on August 3, 2021.
422 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
423 Jenner & Block Interview of J. McDonough on August 10, 2021.
424 Jenner & Block Interview of J. McDonough on August 10, 2021.
425 Jenner & Block Interview of J. McDonough on August 10, 2021.
426 Jenner & Block Interview of J. McDonough on August 10, 2021.
427 Jenner & Block Interview of J. McDonough on August 10, 2021.
428 Jenner & Block Interview of J. McDonough on October 1, 2021.
429 Jenner & Block Interview of J. McDonough on August 10, 2021.
430 Jenner & Block Interview of J. McDonough on October 1, 2021.

94
431Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
432Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
433Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
434 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
435Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
436 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
437 Jenner & Block Interview of J. McDonough on August 10, 2021.
438Jenner & Block Interview of J. McDonough on August 10, 2021; Jenner & Block
Interview of J. McDonough on October 1, 2021.
439 Jenner & Block Interview of J. Quenneville on July 20, 2021.
440Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block
Interview of A. MacIsaac on August 10, 2021; Jenner & Block Interview of J.
McDonough on October 1, 2021; Jenner & Block Interview of J. Gary on September 9,
2021; Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
441 Jenner & Block Interview of J. Quenneville on July 20, 2021.
442 Jenner & Block Interview of J. Quenneville on September 27, 2021.
443Jenner & Block Interview of J. Quenneville on September 27, 2021; Jenner & Block
Interview of J. Quenneville on July 20, 2021.
444 Jenner & Block Interview of J. Quenneville on September 27, 2021.
445 Jenner & Block Interview of J. Quenneville on July 20, 2021.
446 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
447 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
448 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
449 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
450 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.

95
451 Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.
452 Jenner & Block Interview of J. Blunk on July 26, 2021.
453 Jenner & Block Interview of J. Blunk on July 26, 2021.
454 Jenner & Block Interview of J. Gary on September 9, 2021.
455 Blackhawks 2010 Phone Records (May 2010).
456 Jenner & Block Interview of J. Gary on September 9, 2021.
457 Jenner & Block Interview of J. Gary on September 9, 2021.
458 Jenner & Block Interview of J. Gary on September 9, 2021.
459 Jenner & Block Interview of J. Gary on September 9, 2021.
460 Jenner & Block Interview of S. Bowman on September 24, 2021.
461 Blackhawks 2010 Phone Records (May 2010).
462 Jenner & Block Interview of J. Quenneville on September 27, 2021.
463 Jenner & Block Interview of J. Quenneville on September 27, 2021.
464Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
465Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
466Jenner & Block Interview of Witness on August 16, 2021. See generally, Jenner &
Block Interview of Witness on August 11, 2021.
467 Jenner & Block Interview of Witness on August 16, 2021.
468Jenner & Block Interview of S. Bowman on September 24, 2021; Jenner & Block
Interview of A. MacIsaac on September 24, 2021.
469Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview
of B. Sopel on August 12, 2021; Ben Pope, 2010 Blackhawks players widely knew of
Bradley Aldrich’s alleged sexual assault: report, CHICAGO SUN TIMES (June 25, 2021),
https://chicago.suntimes.com/blackhawks/2021/6/25/22550405/blackhawks-
sexual-assault-bradley-aldrich-2010-players-knew-lawsuit; Phil Thompson, Former
Chicago Blackhawks players and staffers allege management likely knew about 2010
sexual assault allegations against video coach, CHICAGO TRIBUNE (June 27, 2021),
https://www.chicagotribune.com/sports/blackhawks/ct-chicago-blackhawks-
sexual-assault-lawsuits-20210627-polnbrjlbnhxra7ecellmhnvim-story.html; Rick

96
Westhead, Sopel: Former Blackhawks teammates should be ‘telling the truth publicly’
about assault allegations, TSN (July 13, 2021), https://www.tsn.ca/sopel-former-
blackhawks-teammates-should-be-telling-the-truth-publicly-about-assault-
allegations-1.1667495.
470 Jenner & Block Interview of B. Sopel on August 12, 2021; Ben Pope, 2010
Blackhawks players widely knew of Bradley Aldrich’s alleged sexual assault: report,
CHICAGO SUN TIMES (June 25, 2021),
https://chicago.suntimes.com/blackhawks/2021/6/25/22550405/blackhawks-
sexual-assault-bradley-aldrich-2010-players-knew-lawsuit.
471Jenner & Block Interview of N. Boynton on July 16, 2021; Rick Westhead, Boynton:
Investigators probing alleged abused of former Blackhawks players ask, ‘Who knew?’,
TSN (July 29, 2021), https://www.tsn.ca/boynton-investigators-probing-alleged-
abuse-of-former-blackhawks-players-ask-who-knew-1.1674971.
472Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview
of B. Sopel on August 12, 2021.
473Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview
of B. Sopel on August 12, 2021.
474Jenner & Block Interview of Witness on July 6, 2021; Jenner & Block Interview of
Witness on July 9, 2021; Jenner & Block Interview of Witness on July 6, 2021; Jenner
& Block Interview of Witness on August 3, 2021; Jenner & Block Interview of Witness
on July 14, 2021; Jenner & Block Interview of Witness on August 31, 2021; Jenner &
Block Interview of Witness on July 16, 2021; Jenner & Block Interview of Witness on
July 13, 2021; Jenner & Block Interview of Witness on September 28, 2021; Jenner &
Block Interview of Witness on August 31, 2021; Jenner & Block Interview of Witness
on July 16, 2021.
475Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview
of B. Sopel on August 12, 2021.
476 Jenner & Block Interview of John Doe on September 20, 2021.
477 Jenner & Block Interview of P. Vincent on August 7, 2021.
478 Jenner & Block Interview of P. Vincent on August 7, 2021.
479 Jenner & Block Interview of N. Boynton on July 16, 2021.
480 Jenner & Block Interview of N. Boynton on July 16, 2021.
Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block Interview of
481

Witness on August 2, 2021.

97
482 Jenner & Block Interview of B. Sopel on August 12, 2021.
483 Jenner & Block Interview of P. Vincent on August 7, 2021.
484 Jenner & Block Interview of P. Vincent on August 7, 2021.
485 Jenner & Block Interview of P. Vincent on August 7, 2021.
486 Jenner & Block Interview of P. Vincent on August 7, 2021.
487 Jenner & Block Interview of Black Ace 1 on August 24, 2010.
488 Jenner & Block Interview of P. Vincent on August 7, 2021.
489 Jenner & Block Interview of P. Vincent on August 7, 2021.
490 Jenner & Block Interview of P. Vincent on August 7, 2021.
491 Jenner & Block Interview of P. Vincent on August 7, 2021.
492 Jenner & Block Interview of P. Vincent on August 7, 2021.
493 Jenner & Block Interview of P. Vincent on August 7, 2021.
494 Jenner & Block Interview of P. Vincent on August 7, 2021.
495 Jenner & Block Interview of Witness on August 10, 2021.
496 Rick Westhead, Former Coach Confirms Blackhawks Management Met to Discuss
Alleged Abuse, TSN.com (June 26, 2021) https://www.tsn.ca/former-coach-confirms-
blackhawks-management-met-to-discuss-alleged-abuse-1.1660541.
497 Jenner & Block Interview of B. Sopel on August 12, 2021.
498Jenner & Block Interview of Witness on July 12, 2021; Blackhawks 2010 Playoffs
Travel Records; Phil Thompson and Christy Gutowski, He helped the Chicago
Blackhawks win the Stanley Cup. But now 2 lawsuits are bringing scrutiny to a former
coach’s behavior around young players, CHICAGO TRIBUNE (September 9, 2021),
https://www.chicagotribune.com/sports/blackhawks/ct-blackhawks-video-coach-
brad-aldrich-history-20210909-o2otulx7uncrlfrlzkrufpe3vy-story.html.
499Jenner & Block Interview of J. McDonough on August 10, 2021; Jenner & Block
Interview of A. MacIsaac on August 10, 2021; Jenner & Block Interview of S. Bowman
on August 12, 2021.
500Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
501 Jenner & Block Interview of Director of Human Resources on August 20, 2021.

98
502Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of B. Aldrich on August 21, 2021.
503See Jenner & Block Interview of J. McDonough on August 10, 2021; Jenner & Block
interview of J. Blunk on July 26, 2021; Jenner & Block Interview of S. Bowman on
August 12, 2021; Jenner & Block Interview of A. MacIsaac on August 10, 2021; Jenner
& Block Interview of Director of Human Resources on August 20, 2021.
504 Jenner & Block Interview of J. McDonough on August 10, 2021.
505 Jenner & Block Interview of S. Bowman on August 12, 2021.
506 Jenner & Block Interview of S. Bowman on August 12, 2021.
507 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
508 Jenner & Block Interview of J. Gary on September 9, 2021.
509 Jenner & Block Interview of J. Gary on September 9, 2021.
510 Jenner & Block Interview of J. Gary on September 9, 2021.
511 Jenner & Block Interview of J. Gary on September 9, 2021.
512 Jenner & Block Interview of J. Gary on September 9, 2021.
513 Jenner & Block Interview of J. Gary on September 9, 2021.
514 Jenner & Block Interview of J. Gary on September 9, 2021.
515 Jenner & Block Interview of J. Gary on September 9, 2021.
516 Jenner & Block Interview of J. Gary on September 9, 2021.
517 Jenner & Block Interview of J. Gary on September 9, 2021.
518 2010 Blackhawks Schedule.
519 2010 Blackhawks Schedule.
Jenner & Block Interview of Witness on July 28, 2021; Jenner & Block Interview of
520

Witness on July 23, 2021; Jenner & Block Interview B. Aldrich on August 21, 2021.
521 Jenner & Block Interview of John Doe on September 20, 2021.
522 Jenner & Block Interview of John Doe on September 20, 2021.
523 Jenner & Block Interview of Witness on July 28, 2021.
524 Jenner & Block Interview of Witness on July 28, 2021.

99
525 Jenner & Block Interview of Witness on July 28, 2021.
526 Jenner & Block Interview of Witness on July 28, 2021.
527 Jenner & Block Interview of Witness on July 28, 2021.
528 Jenner & Block Interview of Witness on July 28, 2021.
529 Jenner & Block Interview of Witness on July 28, 2021.
530 Jenner & Block Interview of Witness on July 28, 2021.
531 Jenner & Block Interview of Witness on July 28, 2021.
532 Jenner & Block Interview of Witness on July 28, 2021.
533 Jenner & Block Interview of Witness on July 28, 2021.
534 Jenner & Block Interview of Witness on July 28, 2021.
535 Jenner & Block Interview of Witness on July 28, 2021.
536 See Jenner & Block Interview of Witness on July 15, 2021; Jenner & Block Interview

of Witness on July 16, 2021; Jenner & Block Interview of Witness on July 20, 2021;
Jenner & Block Interview of Witness on July 14, 2021.
537Jenner & Block Interview of Witness on July 22, 2021; Jenner & Block Interview of
Witness on July 12, 2021; Jenner & Block Interview of Witness on July 14, 2021;
Jenner & Block Interview of Witness on July 26, 2021; Jenner & Block Interview of
Witness on August 31, 2021.
538 Jenner & Block Interview of Witness on July 28, 2021.
539 Jenner & Block Interview of Witness on July 28, 2021.
540 Jenner & Block Interview of Witness on July 28, 2021.
541 Jenner & Block Interview of Witness on July 28, 2021.
542 Jenner & Block Interview of Witness on July 28, 2021.
543 Jenner & Block Interview of Witness on July 28, 2021.
544 Jenner & Block Interview of Witness on July 28, 2021.
545 Jenner & Block Interview of Witness on July 28, 2021.
546 Jenner & Block Interview of Witness on July 28, 2021.

100
547Jenner & Block Interview of Witness on July 28, 2021. This former employee did
not respond to our request for an interview.
548 Jenner & Block Interview of Witness on July 28, 2021.
549 Jenner & Block Interview of Witness on July 28, 2021.
550 Jenner & Block Interview of B. Aldrich on August 21, 2021.
551 Jenner & Block Interview of B. Aldrich on August 21, 2021.
552 Jenner & Block Interview of John Doe on September 20, 2021.
553 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
554 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
555 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
556 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
557 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
558 Chicago Blackhawks Verizon Records (June 2010).
559 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
560 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
561 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
562 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
563 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
564 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
565 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
566 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
567 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
568 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
569 Chicago Blackhawks Verizon Records (June 2010).
570Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of B. Aldrich on August 21, 2021.

101
571Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of B. Aldrich on August 21, 2021.
572 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
573 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
574 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
575 Jenner & Block Interview of Outside Counsel on July 2, 2021.
576 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
577Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of Outside Counsel on July 2, 2021.
578 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
579 Jenner & Block Interview of Outside Counsel on July 2, 2021.
580 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
581 Jenner & Block Interview of B. Aldrich on August 21, 2021.
582 Jenner & Block Interview of B. Aldrich on August 21, 2021.
583 Jenner & Block Interview of B. Aldrich on August 21, 2021.
584 Jenner & Block Interview of B. Aldrich on August 21, 2021.
585 Jenner & Block Interview of B. Aldrich on August 21, 2021.
586 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
587 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
588 Jenner & Block Interview of B. Aldrich on August 21, 2021.
589 June 16, 2010 Separation Agreement of B. Aldrich.
590 Jenner & Block Interview of B. Aldrich on August 21, 2021.
591Jenner & Block Interview of B. Aldrich on August 21, 2021; June 16, 2010
Separation Agreement of B. Aldrich; Hockey Ops Playoff Bonuses 2010; Jenner &
Block Interview of Director of Human Resources on August 20, 2021; July 25, 2008
Employment Agreement of B. Aldrich; Jenner & Block Interview of Witness on
September 2, 2021; July 15, 2010 Chicago Blackhawks Payroll Records, Week 28.
592Jenner & Block Interview of Director of Human Resources on August 20, 2021;
Jenner & Block Interview of B. Aldrich on August 21, 2021.

102
593 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
594 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
595 Jenner & Block Interview of J. McDonough on August 10, 2021.
596 Jenner & Block Interview of A. MacIsaac on August 10, 2021.
597 Jenner & Block Interview of J. Quenneville on July 20, 2021.
598 Jenner & Block Interview of J. Gary on September 9, 2021.
599 Jenner & Block Interview of J. Gary on September 9, 2021.
600 Jenner & Block Interview of John Doe on September 20, 2021.
601 Jenner & Block Interview of John Doe on September 20, 2021.
602 Jenner & Block Interview of John Doe on September 20, 2021.
603 Jenner & Block Interview of John Doe on September 20, 2021.
Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block Interview of
604

Witness on July 30, 2021.

605 Jenner & Block Interview of Witness on July 20, 2021.
606 Jenner & Block Interview of Witness on July 30, 2021.
607 Jenner & Block Interview of Witness on July 28, 2021.
608 Jenner & Block Interview of B. Aldrich on August 21, 2021.
609 Jenner & Block Interview of John Doe on September 20, 2021.
610 Jenner & Block Interview of Director of Human Resources on August 20, 2021.
611 Email from Hockey Hall of Fame to Witnesses re: Cup Schedule (August 18, 2010).
2010 Blackhawks Cup Day Schedule; Jenner & Block Interview of B. Aldrich on
612

August 21, 2021.

613 Jenner & Block Interview of B. Aldrich on August 21, 2021.
614 Jenner & Block Interview of B. Aldrich on August 21, 2021.
615 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block
Interview of Witness on July 28, 2021; Jenner & Block Interview of Witness on July
14, 2021.

103
616 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block
Interview of Witness on July 28, 2021; Jenner & Block Interview of Witness on July
14, 2021.
617 Jenner & Block Interview of B. Aldrich on August 21, 2021; Jenner & Block
Interview of Witness on August 19, 2021.
618 Jenner & Block Interview of B. Aldrich on August 21, 2021.
619 Jenner & Block Interview of Witness on July 30, 2021; Jenner & Block Interview of
Witness on July 16, 2021; Jenner & Block Interview of Witness on July 13, 2021;
Jenner & Block Interview of Witness on August 19, 2021; Jenner & Block Interview of
Witness on August 12, 2021; Jenner & Block Interview of Witness on July 20, 2021;
Jenner & Block Interview of Witness on July 23, 2021; Jenner & Block Interview of
Witness on July 2, 2021; Jenner & Block Interview of Witness on July 9, 2021; Jenner
& Block Interview of Witness on July 13, 2021; Jenner & Block Interview of Witness
on July 8, 2021; Jenner & Block Interview of Witness on July 12, 2021; Jenner & Block
Interview of Witness on July 12, 2021; Jenner & Block Interview of Witness on July
14, 2021; Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block
Interview of Witness on July 23, 2021; Jenner & Block Interview of Witness on August
10, 2021; Jenner & Block Interview of Witness on August 11, 2021; Jenner & Block
Interview of Witness on July 15, 2021; Jenner & Block Interview of Witness on July
21, 2021; Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block
Interview of Witness on July 16, 2021; Jenner & Block Interview of Witness on August
3, 2021; Jenner & Block Interview of Witness on July 9, 2021; Jenner & Block
Interview of Witness on August 30, 2021; Jenner & Block Interview of Witness on July
8, 2021; Jenner & Block Interview of Witness on September 28, 2021.
620See, e.g., Jenner & Block Interview of Witness on July 8, 2021; Jenner & Block
Interview of Witness on July 16, 2021; Jenner & Block Interview of Witness on July
30, 2021; Jenner & Block Interview of Witness on August 2, 2021; Jenner & Block
Interview of Witness on July 20, 2021; Jenner & Block Interview of Witness on August
10, 2021; Jenner & Block Interview of Witness on July 16, 2021; Jenner & Block
Interview of Witness on July 9, 2021; Jenner & Block Interview of N. Boynton on July
16, 2021.
621 Jenner & Block Interview of B. Aldrich on August 21, 2021.
622 Jenner & Block Interview of B. Aldrich on August 21, 2021.
623 Jenner & Block Interview of Witness on September 21, 2021.
624Barnes & Thornburg LLP, Report of Investigation Regarding Former Employee
Bradley Aldrich (September 23, 2021).

104
625Barnes & Thornburg LLP, Report of Investigation Regarding Former Employee
Bradley Aldrich (September 23, 2021).
626 Jenner & Block Interview of Witness on September 27, 2021.
627 Jenner & Block Interview of Witness on September 27, 2021.
628 Jenner & Block Interview of Witness on September 27, 2021.
629 Jenner & Block Interview of Witness on September 27, 2021.
630 Jenner & Block Interview of Witness on September 27, 2021.
631 Jenner & Block Interview of B. Aldrich on August 21, 2021.
632 Jenner & Block Interview of B. Aldrich on August 21, 2021.
633 Jenner & Block Interview of B. Aldrich on August 21, 2021.
634Jenner & Block Interview of Director of Human Resources on July 1, 2021; Email
from the Director of Human Resources to MacIsaac re: Aldrich (March 26, 2012).
635 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
636 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
637 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
638 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
639 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
640 Jenner & Block Interview of Director of Human Resources on July 1, 2021.
641Nicole Walton, Houghton High School Hockey Volunteer Arrested, PUBLIC RADIO 90,
WNMU (October 9, 2013), https://www.wnmufm.org/crime/2013-10-09/houghton-
high-school-hockey-volunteer-arrested.
642 Kurt Hauglie, Aldrich Pleads Guilty, THE DAILY MINING GAZETTE (December 16, 2013),

https://www.mininggazette.com/news/local-news/2013/12/aldrich-pleads-
guilty/.
643Former Volunteer Hockey Coach Sentenced for Sexual Conduct with Student, ABC10
(February 13, 2014), https://abc10up.com/2014/02/13/former-volunteer-hockey-
coach-sentenced-sexual-conduct-student/.
644 Jenner & Block Interview of John Doe on September 20, 2021.
645 Jenner & Block Interview of J. Gary on September 9, 2021.

105
646 Jenner & Block Interview of J. Gary on September 9, 2021.
647 Jenner & Block Interview of John Doe on September 20, 2021.
648 Jenner & Block Interview of J. Gary on September 9, 2021.
649 Jenner & Block Interview of J. Gary on September 9, 2021.
650 Jenner & Block Interview of J. Gary on September 9, 2021.
651 Jenner & Block Interview of John Doe on September 20, 2021.
652 Jenner & Block Interview of John Doe on September 20, 2021.
653 Jenner & Block Interview of John Doe on September 20, 2021.
654 Jenner & Block Interview of John Doe on September 20, 2021.
655 Jenner & Block Interview of John Doe on September 20, 2021.
656 Jenner & Block Interview of John Doe on September 20, 2021.
657Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block
Interview of Witness on August 16, 2021; Jenner & Block Interview of Witness on
September 23, 2021.
658Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
659 Jenner & Block Interview of Witness on August 16, 2021.
660Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
661Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
662Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
663 Jenner & Block Interview of Witness on August 16, 2021.
664Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
665Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview
of Witness on September 23, 2021.
666 Jenner & Block Interview of D. Fehr on October 7, 2021.

106
667 Jenner & Block Interview of Witness on August 16, 2021.
668 Jenner & Block Interview of John Doe on September 20, 2021.
669 Jenner & Block Call with Therapist on October 4, 2021.
670 Jenner & Block Interview of Witness on August 16, 2021.
671 Jenner & Block Interview of Witness on August 16, 2021.
672Jenner & Block Interview of Witness on September 14, 2021; Jenner & Block
Interview of Witness on September 30, 2021.
673Jenner & Block Interview of Witness on September 14, 2021; Jenner & Block
Interview of Witness on September 30, 2021.
674Jenner & Block Interview of Witness on September 14, 2021; Jenner & Block
Interview of Witness on September 30, 2021.
675 Jenner & Block Interview of Witness on September 30, 2021.
676Email from Witness to D. Fehr re: Discussion (April 18, 2011); Jenner & Block
Interview of Witness on September 30, 2021.
677 Jenner & Block Interview of D. Fehr on October 7, 2021.
678 Jenner & Block Interview of Witness on September 30, 2021.
679 Jenner & Block Call with Therapist on October 4, 2021.

107