Report to the Chicago Blackhawks Hockey Team Regarding the

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

I. Executive Summary

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

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.

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

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

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.

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

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.

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,

Illinois by “John Doe,” a former player in the Blackhawks organization, against

the Blackhawks.

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.

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.

On May 26, 2021, a lawsuit was filed in the Circuit Court of Cook County by

“John Doe (2)” against the Blackhawks.

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.

Plaintiff “John Doe

(2)” is described in his complaint as a former player on the Houghton High

School hockey team located in Houghton, Michigan.

“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.

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

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.

 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

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.

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.

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.

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,

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,

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

Aldrich’s counsel participated in our interview of Aldrich.

John Doe’s counsel participated in our interview of John Doe. The

Blackhawks’ civil litigation counsel was also present.

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.

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.

Hindsight bias is defined as the tendency to perceive past events as

being more predictable than they actually were.

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

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).

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.

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

Operations.

In 2010, Kevin Cheveldayoff was the Assistant General Manager;

he has since departed the organization.

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.

Gary is now retired.

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.

He reported to the Blackhawks’ ownership.

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.

When interviewed, McDonough described his

leadership style as aggressive and direct, but denied that all decisions came to

him.

McDonough stated that he generally let the Hockey Operations

employees make the “hockey decisions.”

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

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.

At the time, the Handbook had

last been updated in November 2005.

The Handbook included a harassment

policy, which, among other provisions, prohibited harassing behavior and

required personnel to report harassing behavior by others.

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 …”

“[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.”

Sexual harassment was also defined to include:

“[r]etaliation against an individual for complaining about

sexually harassing behavior.”

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.”

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

determined on a case-by-case basis, after careful review and

consideration of the specific incident(s).”

Players received and were required to acknowledge a document titled “Team

Rules” at the beginning of the 2009-2010 season.

The “Team Rules” were

based on standard rules provided and approved by the NHL and the NHLPA.

The “Team Rules” for the 2009-2010 season did not address sexual

harassment, or reporting, investigation, or discipline for harassment.

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.

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.

During the summer of 2008, the video coach for the Blackhawks transitioned

to a scouting role for the team, leaving the position vacant.

At the time,

Aldrich was the Coordinator of Hockey Operations/Video Coordinator for the

University of Notre Dame Hockey Team.

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.

Tallon recalled that after receiving the

The “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.

message from the Sharks, he received Aldrich’s resume.

Other witnesses

recalled that Tallon was friends with the General Manager of the Sharks and

that Aldrich’s father was the Sharks’ equipment manager.

The then-Director

of Human Resources recalled that Tallon arranged Aldrich’s interview for the

video coach position.

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.

Aldrich recalled Bowman describing a video coach position and inviting

Aldrich to interview for the position.

When interviewed, Bowman said he

did not recall being involved in Aldrich’s interview or hiring process.

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.

Bowman said that he did not know how Aldrich became an employee of the

Blackhawks.

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.

Aldrich recalled being interviewed by Tallon in his office, and

meeting Bowman and McDonough, both of whom Aldrich said stopped by

Tallon’s office.

The Director of Human Resources also recalled interviewing

Aldrich.

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.

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.

Aldrich was employed as the video coach for the Blackhawks from August 1,

2008, until June 16, 2010.

He reported directly to the head coach, who was

initially Denis Savard and later Joel Quenneville.

Aldrich and some players

and coaches recalled that players could request their individual video clips

from Aldrich.

Aldrich gave the requested clips to the coaches, who would in

turn show the clips to the players.

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.

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.

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.”

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.”

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!”

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.

He further stated that the review

looked to him like something he would write.

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,

outgoing,

and nice.

Several former players and coaches viewed Aldrich’s work

performance positively.

Witnesses noted that Aldrich got along well with the

coaches and was “chummy” with many individuals on the Blackhawks’ staff.

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.

Other witnesses had very different views of Aldrich. One former player

described Aldrich as intense and “cocky.”

Some witnesses described Aldrich

as “creepy,”

someone who kept to himself,

peculiar,

standoffish, and

arrogant.

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.

Some witnesses

observed Aldrich “hitting on” female Front Office employees.

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.

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.

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.

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.

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).

The Blackhawks won the Stanley Cup Finals against the

Philadelphia Flyers on June 9, 2010.

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:

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.

A Black Ace

would play only if the Blackhawks had already depleted available back-up

players on the NHL roster, a very unlikely eventuality.

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.

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.

Members of the Rockford IceHogs’ coaching and training staff traveled

to Chicago to support the Black Aces.

The Rockford staff, however, did not

travel with the Black Aces to away games.

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.

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.

Several witnesses recalled observing

Aldrich with the Black Aces.

Some former Black Aces recalled Aldrich

hosting several Black Aces at the pool at his apartment building,

hosting

Black Aces inside his apartment,

and gathering as a group for massages at

the team hotel on the road.

Phone records corroborate that Aldrich and

multiple Black Aces were in frequent contact with each other in May and June

of 2010.

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.

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.

One member of the 2010 Blackhawks team recalled that many players relied

on Aldrich to tell them what coaches were thinking.

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.

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.

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.

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.”

Six additional witnesses told us that, after

Aldrich’s separation from the Blackhawks, each heard a rumor that Aldrich

threatened players’ careers.

***

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.

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,

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.

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

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

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

As 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.

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

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

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

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.”

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

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

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

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

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

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

minutes, and several calls were only one minute in duration

268

—which could

indicate no connection was made or a voicemail was left.

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

For 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.

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

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

(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.

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.

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

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

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.

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

Phone 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.

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

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.

John 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.

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

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

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

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

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

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

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

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

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

Former Blackhawks players Brent Sopel and Nick Boynton publicly

identified themselves in 2021 and made public statements about their

knowledge of certain events.

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

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.

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

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

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

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

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

3. Aldrich’s Separation from the Blackhawks Organization

On the morning of June 16, 2010, Aldrich met with the Director of Human

Resources

571

and the Blackhawks’ outside counsel, whom the Director of

Human Resources had informed about the situation.

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

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.

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

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

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

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

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

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

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

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.

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

Aldrich 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.

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

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.

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.

***

Appendix

Photo Credits: Chicago Blackhawks

June 9, 2010: Brad Aldrich with the Stanley Cup

June 9, 2010

From left: Paul Vincent; John Torchetti; Stephane Waite; Joel Quenneville;

Mike Haviland; Brad Aldrich.

June 11, 2010: Stanley Cup Parade in Chicago

From left: Al MacIsaac; John McDonough; Brad Aldrich; Paul Vincent.

June 13, 2010: The Stanley Cup at Wrigley Field in Chicago; Aldrich identified

with green circle.

Endnotes

Complaint, John Doe v. Chicago Blackhawk Hockey Team, Inc., No. 2021 L 004728

(Cook Cnty. Cir. Ct. May 7, 2021) (“Doe (1) Complaint”).

Doe (1) Complaint, Count I, ¶¶ 1-12; Count II, ¶¶ 1-15; Count III, ¶¶ 1-9.

First 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”).

Complaint, John Doe (2) v. Chicago Blackhawk Hockey Team, Inc., No. 2021 L 005435

(Cook Cnty. Cir. Ct., May 26, 2021) (“Doe (2) Complaint”).

Doe (2) Complaint, Count I, ¶¶ 1-11; Count II, ¶¶ 1-11.

Doe (2) Complaint, Counts I-II, ¶ 1.

First 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).

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.

Raymond S. Nickerson, Confirmation Bias: A Ubiquitous Phenomenon in Many Guises,

2 REVIEW OF GENERAL PSYCHOLOGY, no. 2, 1998, at 175.

Neal J. Roese and Kathleen D. Vohs, Hindsight Bias, 7 PERSPECTIVES ON PSYCHOLOGICAL

SCIENCE, no. 5, 2012, at 411.

Jenner & Block Interview of S. Bowman on August 12, 2021.

Jenner & Block Interview of A. MacIsaac on August 10, 2021.

Jenner & Block Interview of K. Cheveldayoff on August 5, 2021.

Jenner & Block Interview of J. Gary on September 9, 2021.

Jenner & Block Interview of J. McDonough on August 10, 2021.

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.

Jenner & Block Interview of J. McDonough on August 10, 2021.

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.

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 5(b)(i)-(iii).

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 6(y).

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 6(y).

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 6(y).

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 6(y).

Chicago Blackhawks Hockey Team, Team Member Handbook, November 2005,

¶ 6(y).

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

Witness to Jenner & Block.

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

Witness to Jenner & Block.

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.

Blackhawks 2008 Video Coach Job Description; Jenner & Block Interview of B.

Aldrich on August 21, 2021.

Jenner & Block Interview of Witness on July 13, 2021.

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

Jenner & Block Interview of D. Tallon on August 24, 2021.

Jenner & Block Interview of A. MacIsaac on August 10, 2021; Jenner & Block

Interview of P. Vincent on August 7, 2021.

Jenner & Block Interview of Director of Human Resources on August 20, 2021.

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

Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block

Interview of S. Bowman on September 24, 2021.

Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block

Interview of S. Bowman on September 24, 2021.

Jenner & Block Interview of S. Bowman on August 12, 2021; Jenner & Block

Interview of S. Bowman on September 24, 2021.

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

Jenner & Block Interview of Director of Human Resources on August 20, 2021.

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.

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

July 25, 2008 Employment Agreement of B. Aldrich; June 16, 2010 Separation

Agreement of B. Aldrich.

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

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.

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 B. Aldrich on August 21, 2021.

January 2, 2009 Performance Evaluation of B. Aldrich.

June 3, 2009 Performance Evaluation of B. Aldrich

June 29, 2010 Performance Evaluation of B. Aldrich.

Jenner & Block Interview of J. Quenneville on September 27, 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 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

Witness on July 12, 2021; Jenner & Block Interview of Witness on July 26, 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 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.

Jenner & 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

Witness on July 9, 2021.

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

Witness on July 6, 2021; Jenner & Block Interview of Witness on July 16, 2021.

Jenner & Block Interview of Witness on July 29, 2021.

Jenner & Block Interview of Witness on July 15, 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 July 20, 2021; Jenner & Block Interview of

Witness on July 13, 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 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.

Jenner & Block Interview of Witness on July 14, 2021; Jenner & Block Interview of

A. MacIsaac on August 10, 2021.

Jenner & Block Interview of Witness on July 6, 2021.

Chris 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.

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”).

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.

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),

https://nypost.com/2010/05/23/blackhawks-finish-off-sharks-advance-to-stanley-

cup/.

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.

Jenner & 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.

Jenner & 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 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.

Jenner & 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

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

Manifest; Rockford Staff - Black Aces Coverage.

Jenner & 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.

Jenner & Block Interview of B. Aldrich on August 21, 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 14, 2021;

Jenner & Block Interview of Witness on September 10, 2021.

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

of Witness on July 29, 2021.

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

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

of Black Ace 1 on August 24, 2021.

Chicago Blackhawks Verizon Phone Records (May-June 2010).

Jenner & Block Interview of John Doe on September 20, 2021.

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

Witness on July 6, 2021.

Jenner & Block Interview of Witness on July 16, 2021.

Jenner & Block Interview of Black Ace 1 on August 24, 2021.

Jenner & 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.

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.

120

Blackhawks 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.

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.

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.

176

Jenner & 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.

181

Jenner & 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.

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.

196

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on August 11, 2021.

197

Jenner & 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.

199

Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block

Interview of Black Ace 1 on August 24, 2021.

200

Jenner & Block Interview of John Doe on September 20, 2021; Jenner & Block

Interview of Black Ace 1 on August 24, 2021.

201

Jenner & 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.

203

Jenner & 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.

205

Jenner & 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.

207

Jenner & 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.

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.

217

Jenner & 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.

227

Jenner & 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.

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.

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;

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.

302

Email 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.

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.

313

Jenner & 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.

327

Jenner & 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.

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.

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.

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.

392

Jenner & 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.

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.

418

Jenner & 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.

431

Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner

& Block Interview of Director of Human Resources on August 20, 2021.

432

Jenner & Block Interview of Director of Human Resources on July 1, 2021; Jenner

& Block Interview of Director of Human Resources on August 20, 2021.

433

Jenner & 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.

435

Jenner & 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.

438

Jenner & 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.

440

Jenner & 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.

443

Jenner & 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.

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.

464

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on September 23, 2021.

465

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on September 23, 2021.

466

Jenner & 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.

468

Jenner & Block Interview of S. Bowman on September 24, 2021; Jenner & Block

Interview of A. MacIsaac on September 24, 2021.

469

Jenner & 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

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.

471

Jenner & 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.

472

Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview

of B. Sopel on August 12, 2021.

473

Jenner & Block Interview of N. Boynton on July 16, 2021; Jenner & Block Interview

of B. Sopel on August 12, 2021.

474

Jenner & 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.

475

Jenner & 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.

481

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

Witness on August 2, 2021.

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.

498

Jenner & 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.

499

Jenner & 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.

500

Jenner & 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.

502

Jenner & Block Interview of Director of Human Resources on August 20, 2021;

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

503

See 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.

520

Jenner & Block Interview of Witness on July 28, 2021; Jenner & Block Interview of

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.

100

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.

537

Jenner & 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.

101

547

Jenner & 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).

570

Jenner & Block Interview of Director of Human Resources on August 20, 2021;

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

102

571

Jenner & 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.

577

Jenner & 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.

591

Jenner & 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.

592

Jenner & Block Interview of Director of Human Resources on August 20, 2021;

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

103

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.

604

Jenner & Block Interview of Witness on July 20, 2021; Jenner & Block Interview of

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).

612

2010 Blackhawks Cup Day Schedule; Jenner & Block Interview of B. Aldrich on

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.

104

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.

620

See, 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.

624

Barnes & Thornburg LLP, Report of Investigation Regarding Former Employee

Bradley Aldrich (September 23, 2021).

105

625

Barnes & 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.

634

Jenner & 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.

641

Nicole 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/.

643

Former 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.

106

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.

657

Jenner & 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.

658

Jenner & 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.

660

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on September 23, 2021.

661

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on September 23, 2021.

662

Jenner & 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.

664

Jenner & Block Interview of Witness on August 16, 2021; Jenner & Block Interview

of Witness on September 23, 2021.

665

Jenner & 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.

107

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.

672

Jenner & Block Interview of Witness on September 14, 2021; Jenner & Block

Interview of Witness on September 30, 2021.

673

Jenner & Block Interview of Witness on September 14, 2021; Jenner & Block

Interview of Witness on September 30, 2021.

674

Jenner & 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.

676

Email 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.