Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD.,

KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS HOCKEY CLUB INC., 2325224 ONTARIO INC.

o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY

ACADEMY LTD., OTTAWA 67'S LIMITED PARTNERSHIP c.o.b. OTTAWA 67's HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES

LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY WOLVES HOCKEY CLUB

LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as BRANDON WHEAT KINGS, BRANDON

WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY SPORTS AND ENTERTAINMENT CORPORATION,

EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB, INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA

ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS & ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS

LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY

PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT

TIGERS, SWIFT CURRENT TIER 1 FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS &

ENTERTAINMENT INC. o/a WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC.

WARRIORS o/a MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB, 649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A

HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND

INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES

OLYMPIQUES DE GATINEAU INC., HALIFAX MOOSEHEADS HOCKEY CLUB

INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE

CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS,

LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a

CATARACTES SHAWNIGAN, CLUB DE HOCKEY JUNIOR MAJEUR VAL D’OR INC. o/a VAL D'OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY

LE PHOENIX, 9264-8849 QUÉBEC INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS

HOCKEY c.o.b. FLINT FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE

THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY AMERICANS HOCKEY LLC,

and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

REPLY MOTION RECORD (CERTIFICATION MOTION RETURNABLE FEB. 14-18, 2022)

KOSKIE MINSKY LLP900-20 Queen Street West Toronto, ON M5H 3R3

James Sayce LSO#: 58730MTel: 416-542-6298 Fax: 416-204-2809 jsayce@kmlaw.ca

Nathalie Gondek LSO#: 77660H Tel: 416-542-6286 ngondek@kmlaw.ca

Sue Tan LSO#: 74826ATel: 416-595-2117 ngondek@kmlaw.ca

Lawyers for the Plaintiffs

TO: BENNETT JONES LLP 3400-1 First Canadian Place PO Box 130 Toronto, ON M5X 1A4

Ranjan Agarwal LSO#: 49488H Tel: 416-777-6503 Fax: 416-863-1716

Mike Eizenga LSO#: 31470TTel: 416-777-4879 Fax: 416-863-1716

Lawyers for the Defendants

TABLE OF CONTENTS

Tab Document Page

1. Affidavit of Daniel Carcillo, sworn November 26, 2021 1

Exhibit A – copy of article by Jamie Strashin of CBC News, dated November 29, 2018

6

Exhibit B – excerpt of transcript of the embedded CBC News interviews 12

Exhibit C – copy of Yahoo News article titled, "Junior Hockey Needs Overhaul when 'it's not easy to ask for help' ", dated March 19, 2014

15

Exhibit D – copy of text messages between Daniel Carcillo and David Branch

23

2. Affidavit of Brad Hammett, sworn November 26, 2021 28

Exhibit A – copy of email correspondence between Brad Hammett and Ron Robison

33

Exhibit B – copy of CHL Press Release, dated July 26, 2020 40

Exhibit C – copy of article titled, "Hammett joining proposed class-action lawsuit against the CHL", by Rick Westhead dated June 26, 2020

42

Exhibit D – copy of email correspondence from Ron Robison, dated July 2, 2020

46

Exhibit E – copy of correspondence from Brian Beresh, dated July 7, 2020 48

3. Affidavit of Jay Johnson, sworn November 29, 2021 52

Exhibit A – copy of Reply Report 55

Exhibit B – copy of curriculum vitae 63

Exhibit C – Acknowledgement of Experts Duty 97

4. Affidavit of Catherine MacDonald, sworn November 29, 2021 103

Exhibit A – copy of excerpt from the book titled, "Playing with Fire" by Theo Fleury.

106

Exhibit B – copy of excerpt from the book titled, "I Am Nobody" by Greg Gilhooly.

126

Exhibit C – copy of an excerpt from the book titled, "Why I Didn’t Say Anything" by Sheldon Kennedy.

140

Exhibit D – copy of excerpt from the book titled, "Crossing the Line" by Laura Robinson.

190

TABLE OF CONTENTS

Exhibit E – copy of the articled titled, "RCMP office in jail-sex case 'dysfunctional,' court hears" dated September 18, 2014.

219

Exhibit F - copy of the report following a public interest investigation into an incident occurring in the Kamloops, British Columbia cell, File No. PC-2010-3263

222

Exhibit G – copy of article titled, "Top Mountie on defensive after cell sex accusation"

258

Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR

HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD., KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS

HOCKEY CLUB INC., 2325224 ONTARIO INC. o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY

BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY ACADEMY LTD., OTTAWA 67’S LIMITED PARTNERSHIP c.o.b. OTTAWA

67’s HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY

WOLVES HOCKEY CLUB LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as

BRANDON WHEAT KINGS, BRANDON WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY

SPORTS AND ENTERTAINMENT CORPORATION, EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB,

INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS

& ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER

JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA

ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT TIGERS, SWIFT CURRENT TIER 1

FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS & ENTERTAINMENT INC. o/a

WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC. WARRIORS o/a

MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB,

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

001

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649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE

TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE

BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES OLYMPIQUES DE GATINEAU INC.,

HALIFAX MOOSEHEADS HOCKEY CLUB INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA

INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-

NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS, LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN

MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a CATARACTES SHAWNIGAN, CLUB DE HOCKEY

JUNIOR MAJEUR VAL D’OR INC. o/a VAL D’OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY LE PHOENIX, 9264-8849 QUÉBEC

INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS HOCKEY c.o.b. FLINT

FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY

AMERICANS HOCKEY LLC, and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

AFFIDAVIT OF DANIEL CARCILLO (Sworn November ____, 2021)

I, Daniel Carcillo, of the City of Homer Glen, in the State of Illinois, in the United

States of America, MAKE OATH AND SAY:

1. I am a proposed representative plaintiff in this action. I swore an affidavit in

support of my certification motion on August 27, 2020 (my “Original Affidavit”). David

Branch swore an affidavit dated November 1, 2021 in response to my Original Affidavit.

I swear this affidavit in reply to Mr. Branch’s Affidavit.

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26

002

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2. I disagree with many of Mr. Branch’s statements in his affidavit. I will not address

every statement I disagree with, but will focus on what happened after I reported my abuse

in 2003, and what happened after I reported my abuse in 2018. Mr. Branch’s evidence in

both regards is false.

3. Contrary to what Mr. Branch says at paragraph 17 of his affidavit, during my time

in the league, the OHL and the OHL Teams did not take hazing very seriously at all. I

know this from what happened when the league found out about the abuse on my team,

but also from my conversations with other players on other teams.

4. I do not think that Mr. Branch or anybody at the OHL cared about the abuse my

teammates and I reported in 2003. Contrary to what Mr. Branch says, the OHL did not

address it. There were no “mandatory policies and programs” at either the team or league

level that I am aware of. If they existed, nobody told me about them. Jeff Perry, the Sarnia

Sting head coach who watched and took part in our abuse, was not sanctioned in any way

after we reported our abuse. It appears that Mr. Branch’s response to our reporting of the

abuse was for him to ask Mr. Perry what happened and he accepted Mr. Perry’s staunch

refusal of any wrongdoing at face value. The “investigation” started and ended there.

5. I am also very concerned with Mr. Branch’s description of our 2019 meeting in

Toronto at paragraphs 40 and 41 of his affidavit. The following statement is simply untrue:

“I was unaware of Mr. Carcillo’s allegations relating to hazing until….in and around June

2020”.

6. I went public with detailed allegations of abuse while I played for the Sarnia Sting

in late 2018, as I described in my Original Affidavit at paragraphs 18 and 19. I tweeted

about it, and it made national news. My teammates corroborated my story and shared their

own stories of abuse, which was also reported on by the press. Mr. Branch even publicly

apologized in 2018. This took place approximately 1.5 years before I commenced this

class proceeding.

7. I attach an article published by Jamie Strashin of CBC News dated November 29,

2018, in which Mr. Branch admitted that the CHL had failed me and my teammates, at

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

003

- 4 -

Exhibit “A”. I also attach an excerpted transcript of the embedded CBC National

Television News story which includes separate interviews with me and Mr. Branch on the

very topic of the abuse I had reported, at Exhibit “B”. In the interview, Mr. Branch states

“We had failed Dan and the other players involved, in my view.”

8. My 2019 meeting with Mr. Branch took place after my stories of hazing and abuse

made national news in the United States and Canada. Our 2019 meeting was to discuss

my potential involvement in rooting out hazing, abuse and toxic culture in the OHL, as an

abuse survivor and a Stanley Cup winner. I thought that current players may feel more

comfortable breaking the junior hockey code of silence with me given my stature in the

hockey world. We discussed the OHL Player Liaison Program specifically, which would

allow me to be an intermediary with players who are struggling with the abuse and other

cultural issues in Junior Hockey. I was and still am of the view that the OHL Player Liaison

Program is most likely ineffective due to the pressures of the junior hockey code of silence.

I attach a news article from Yahoo News from 2014 which speaks to the ineffectiveness

of the Player Liaison Program at Exhibit “C”.

9. I attach my last text messages between me and Mr. Branch at Exhibit

“D” where I thanked him for meeting with me in December 2019, and I explicitly refer to

our discussion of my offer to get involved in the Player Liason Program.

10. I asked to meet with Mr. Branch so I could help. This offer fell on deaf ears.

11. For Mr. Branch to swear that I “did not refer to any of the allegations he now makes

about the hazing he experienced” at our 2019 meeting is shocking to me. Mr. Branch and

I had a very public conversation about abuse in junior hockey only months before this

meeting. His suggestions that “I did not get in touch with him with suggestions for further

changes to our policies and programs” is also untrue – I tried to contact Mr. Branch after

our meeting, he simply did not respond to me.

12. Mr. Branch’s affidavit makes clear that he was aware of what happened to me and

my teammates in 2003 and he did nothing to help. He was reminded of my abuse in 2018

through press coverage and he apologized, but took no steps to change the system. We

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004

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met in 2019, where he was reminded once again, and I prompted him to take action, but

he once again balked at this opportunity. In my view, his sworn statement that he was not

aware of my abuse until I commenced this lawsuit in 2020 is preposterous and reflects the

ongoing culture of silence in Junior Hockey.

13. I swear this affidavit in support of my motion to certify this action as a class

proceeding and for no other or improper purpose.

SWORN by Daniel Carcillo, via video-link

from the City of Homer Glen, in the State of

Illinois, in the United States of America,

before me in the City of Toronto, in the

Province of Ontario, on November ___, 2021,

in accordance with O. Reg. 431/20,

Administering Oath or Declaration Remotely.

DANIEL CARCILLO

A Commissioner for taking Affidavits (or as may be)

NATHALIE GONDEK LSO #: 77660H

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005

THIS IS EXHIBIT “A” REFERRED TO IN THE AFFIDAVIT OF DANIEL CARCILLO SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF HOMER GLEN, IN THE

STATE OF ILLINOIS, IN THE UNITED STATES OF AMERICA, TO THECITY OF TORONTO, IN THE PROVINCE OF ONTARIO, THIS _____TH DAY

OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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26

006

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007

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008

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009

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010

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011

THIS IS EXHIBIT “B” REFERRED TO IN THE AFFIDAVIT OF DANIEL CARCILLO SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF HOMER GLEN, IN THE

STATE OF ILLINOIS, IN THE UNITED STATES OF AMERICA, TO THECITY OF TORONTO, IN THE PROVINCE OF ONTARIO, THIS _____TH DAY

OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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012

6106064_1

Transcribed Excerpts of Video Interviews

(embedded at https://www.cbc.ca/sports/hockey/nhl/david-branch-daniel-carcillo-ohl-sarnia-sting-haze-1.4926593)

Reporter: The acknowledgement and the apology came quickly. David Branch admits the Ontario Hockey League failed to protect its players.

Branch: Totally repulsive, the stories, so much disappointment. We had failed Dan and other players involved, in my view, and its shocking you know I don’t know how else to put it.

Carcillo: One of my teammates being taped to a table ass up, naked, being whipped with his own belt.

Reporter: The revelations unraveled this week when former NHLer Dan Carcillo disclosed the abuse he experienced and witnessed as a teenager while playing with the Sarnia Sting.

Carcillo: We had to endure that abuse, that daily abuse and it was something that I thought was normal that everybody else was going through.

Reporter: Carcillo says he hit a breaking point after an initiation called the sweat box, he and several other rookies were stuffed naked into a bus bathroom. He complained to managers. Branch says he did go to Sarnia to investigate and was told nothing serious had happened.

Branch: We didn’t know, if we had we would have acted, and we hopefully are in a better place today because of the programs that we put in place to support the players.

[background interview]

Reporter: Branch says the league cracked down on hazing when it did learn about it. The trigger was an incident in 2005 that made headlines involving the Windsor Spitfires. The coaches were suspended, the team fined thousands of dollars. But Carcillo says a toxic hockey culture kept the lid on other incidents and in the last week his former rookie teammates have come forward, including Ryan Muntz and Charles Amodeo, all say the head coach at the time Jeff Perry was well aware of the abuse.

Does that suggest to you that the people who were there, the coaches, didn’t think this was serious enough to report?

Branch: If it occurred, and I have no reason to doubt the young men where the was a real breakdown maybe, is the players didn’t really know who to trust and turn to. There was certainly some people not expressing themselves and providing proper leadership.

Reporter: And what's your message to them?

Branch: Come forward.

Reporter: Is that message directed to Jeff Perry?

Branch: He's the head coach at that time, yes.

Reporter: And what would you want to hear from him?

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Page 2

Branch: I'd let him to decide, I don’t want to tell him what he shouldn’t say, he should know what to say.

Reporter: Perry didn’t respond to our questions. But Carcillo told us Perry called him this evening to offer an apology. Carcillo says he is not sure he can accept it. Ioanna Roumeliotis, CBC News Toronto.

Daniel Carcillo's former teammate echoes hazing abuse allegations

…starting from 2:30

Munce: ….We were on Team Canada at the time, at the end of the year, and we were discussing it with other people on Team Canada and all discussing what we had as rookies, and at the end of it everybody was just zoned in on me and him, and everything we went through, and you know, our coach called David Branch and Branch actually stepped up at the end of it and called it out, but you know it was more like we had to like hide it, like we weren’t allowed to really come out and express it, so we actually had to kind of say no, like nobody knew about it, like you know it was just like a couple of bats like it wasn’t a big deal, but in reality it was awful – everybody knew ya know. Everybody knew something was going – at least something was going on and to a more extent participated in.

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THIS IS EXHIBIT “C” REFERRED TO IN THE AFFIDAVIT OF DANIEL CARCILLO SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF HOMER GLEN, IN THE

STATE OF ILLINOIS, IN THE UNITED STATES OF AMERICA, TO THECITY OF TORONTO, IN THE PROVINCE OF ONTARIO, THIS _____TH DAY

OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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015

11/26/21, 11:44 AM Junior hockey needs overhaul when 'it's not easy to ask for help'

https://news.yahoo.com/junior-hockey-needs-overhaul-when--it-s-not-easy-to-ask-for-help--200313784.html 1/7

Junior hockey needs overhaul when 'it'snot easy to ask for help'

March 19, 2014

The memory Connor Brown keeps closest to his heart these days is the

one involving his friend Terry Trafford. The pair first met when they were

minor hockey teammates and spent four years playing together as kids.

“One time I went over to his house and hung out with him all day,” said the

Erie Otters captain, now 20. “We were young, so I think we were playing

with his slot cars. It’s just a little memory, but it’s something that sticks

out in my mind about him.”

Terry Trafford was laid to rest on Tuesday at a service in his hometown of

Toronto.

Trafford’s body was found on March 11 in his truck. Police determined the

Saginaw Spirit forward died of self-inflicted asphyxiation. The 20-year-old

had reportedly suffered from depression and had been distraught over

being cut by the Spirit after four years of Ontario Hockey League service.

Brown, like so many others, is wondering how this could have happened

to a guy known for his big smile and happy demeanor.

“It becomes an all-or-nothing feeling because of the status that hockey

has and how obsessed young people get with thinking this is their destiny

and the only thing that’s worthwhile,” said noted sports psychologist, Dr.

Cal Botterill. “I think when we think that way it’s dangerous.”

Botterill understands the demands and culture of hockey better than

most. In addition to working with teams in the National Hockey League

for more than a decade, he’s a former national team player himself. His

daughter, Jennifer, is a three-time Olympic gold medallist with the

women’s national team and his son, Jason, is a former NHLer who

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11/26/21, 11:44 AM Junior hockey needs overhaul when 'it's not easy to ask for help'

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currently serves as the assistant general manager of the Pittsburgh

Penguins.

He believes hockey needs a culture change in order to start better serving

the needs of players.

“I think it’s going to take a while because the whole macho attitude is still

there so prominently,” said Botterill. “If it ever slips, Don Cherry reminds

us, so it’s constantly there that it’s a macho sport.

“The most important things are probably long-term things starting with

kids.”

The perception of the macho, tough hockey player is sometimes so

prevalent that players are afraid to ask for help, even if they know they

need it, out of fear they’ll be seen as weak.

“You’re on a team of alpha males so to speak,” said Brown, a Toronto

Maple Leafs prospect. “It’s not easy to ask for help when you need it, but

there have been a lot of cases – and in this case recently — where we

definitely need something to show for it. It’s really important.”

OHL commissioner David Branch told Yahoo’s Neate Sager each of the

league’s 20 teams is required to have a player liaison program. The liaisonliai liai

is a person in the community that a player can speak to confidentially.

The liaison, however, is not required to have any kind of mental healthliai

training.

But any kind of program is only good when people know it’s available.

Yahoo Sports contacted 15 players from both OHL conferences to ask if

they knew about the player liaison program prior to Trafford’s death. Ofliai

those 15 players – across more than half the league – not a single one said

they knew about the program. All of them, however, said they would

consider using such a program if they ever felt they needed it. Brown was

not asked to participate as he was quoted for this story.

Currently only the Quebec Major Junior Hockey League has a dedicated

toll-free hotline available to players. The phone line is run by Natacha

Llorens, the director of the QMJHL’s player support program. The hotline

is staffed 24-hours a day, strictly confidential and has health care

professionals – including those trained in mental health issues – readily

available.

“When you get to the elite leagues like junior, we should be doing a little

better job of detection,” said Botterill. “A better job of making sure people

know there’s always someone you can talk to, because some illnesses

need medication, but some illnesses just need a good friend.

“As soon as you have a friend that you can trust and you share something

and the person says, ‘I think I can understand how you feel,’ there’s a huge

relief right away, because someone has acknowledged that you feel that

way”

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11/26/21, 11:44 AM Junior hockey needs overhaul when 'it's not easy to ask for help'

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way.

The key, however, is for a person to first realize there is a problem in

order to address many mental health issues. The difficulty in

acknowledging depression before even asking for help is far more

complicated than most people understand.

“The problem with anything is if you’re feeling a certain way – and it isn’t

great – maybe you’ve never felt anything better,” said the professor at the

University of Winnipeg. “So you don’t go and look for help and it might be

quite serious. You might be more depressed than most people, but if you

don’t know what feeling good feels like, then it’s hard to know to reach

out.”

When Botterill worked with NHL teams they would often hold sessions

for player's wives and girlfriends because people are more likely to

confide in a partner. In Trafford’s case, it was his girlfriend, Skye Cieszlak,

who he entrusted with the knowledge of his depression.

Botterill believes junior teams need to do more to better protect and

prepare players for life after hockey considering so few will ever make it

to the NHL. There needs to be more done to make sure players are better

rounded – particularly through teams working with schools – to ensure

hockey doesn’t feel like everything in life.

“Some of those people who were successful early on have even bigger

trouble because when it starts to disappear on them they get desperate,”

Botterill explained. “They know no other life and no other identity. It’s a

scary business. I think it’s happened a lot more than we think until we

start adding it up how many people has this kind of thing happened to,

and it’s been a lot.”

The teenage years, even without the added pressures of hockey, are

already a volatile period of most young people.

“Self-image becomes so important and a lot of time there isn’t a lot of

basis for self-acceptance which is probably more important,” said

Botterill.

“They’re running around so hard in the teenage years to be liked and to be

successful and so on – sometimes those obsessions take them down

paths that are not very healthy and can sometimes lead to this kind of

self-destruction.”

Sunaya Sapurji is the Junior Hockey Editor at Yahoo! Sports.

Email: sunaya@yahoo-inc.com | Twitter @Sunayas

Our goal is to create a safe and engaging place for users to connect over interests and passions. In order to improve ourcommunity experience, we are temporarily suspending article commenting

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THIS IS EXHIBIT “D” REFERRED TO IN THE AFFIDAVIT OF DANIEL CARCILLO SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF HOMER GLEN, IN THE

STATE OF ILLINOIS, IN THE UNITED STATES OF AMERICA, TO THECITY OF TORONTO, IN THE PROVINCE OF ONTARIO, THIS _____TH DAY

OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

26

023

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

024

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

025

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

026

Carcillo et al. Plaintiffs and

Canadian Hockey League et al. Defendants Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

Proceeding commenced at TORONTO

AFFIDAVIT OF DANIEL CARCILLO (SWORN NOVEMBER 26, 2021)

KOSKIE MINSKY LLP900-20 Queen Street West Toronto ON M5H 3R3

James Sayce LSO#: 587630M jsayce@kmlaw.ca Tel: 416-542-6298

Nathalie Gondek LSO#: 77660H ngondek@kmlaw.ca Tel: 416-542-6286

Sue Tan LSO#: 74826A stan@kmlaw.ca Tel: 416-595-2117

Lawyers for the Plaintiffs

DocuSign Envelope ID: 0E5BD552-1A5B-4927-823D-4DA2405810AD

027

Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR

HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD., KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS

HOCKEY CLUB INC., 2325224 ONTARIO INC. o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY

BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY ACADEMY LTD., OTTAWA 67’S LIMITED PARTNERSHIP c.o.b. OTTAWA

67’s HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY

WOLVES HOCKEY CLUB LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as

BRANDON WHEAT KINGS, BRANDON WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY

SPORTS AND ENTERTAINMENT CORPORATION, EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB,

INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS

& ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER

JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA

ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT TIGERS, SWIFT CURRENT TIER 1

FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS & ENTERTAINMENT INC. o/a

WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC. WARRIORS o/a

MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB,

028

- 2 -

649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE

TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE

BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES OLYMPIQUES DE GATINEAU INC.,

HALIFAX MOOSEHEADS HOCKEY CLUB INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA

INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-

NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS, LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN

MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a CATARACTES SHAWNIGAN, CLUB DE HOCKEY

JUNIOR MAJEUR VAL D’OR INC. o/a VAL D’OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY LE PHOENIX, 9264-8849 QUÉBEC

INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS HOCKEY c.o.b. FLINT

FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY

AMERICANS HOCKEY LLC, and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

AFFIDAVIT OF BRAD HAMMETT (Sworn November__, 2021)

I, Brad Hammett, of the City of St. Albert, in the Province of Alberta MAKE

OATH AND SAY:

1. I swore an affidavit in support of the certification motion in this proposed class

proceeding, dated August 11, 2020 (my “Original Affidavit”). I have now reviewed the

affidavit of Ron Robison, commissioner of the WHL, which was sworn in response to the

certification record. I swear this affidavit in support of the certification motion and for no

other or improper purpose.

029

- 3 -

2. When I read about this class proceeding in the news, I was reminded of the abuse

that I suffered while playing the WHL. I provided a description of the sexual abuse I

suffered in my Original Affidavit. My first thought was to contact the WHL to explain

what happened to me, rather than taking part in the class proceeding.

3. On June 20, 2020, I sent the WHL general email address an email outlining the

abuse I suffered. I explained who had abused me and the circumstances surrounding it. I

subsequently had a telephone call with Mr. Robison, Richard Doerksen (Vice-President,

Hockey WHL), and a PR person whose name I do not remember. This phone call took

place on June 24, 2020.

4. On that June 24 telephone call, Mr. Robison and Mr. Doerksen told me that they

were conducting an internal investigation, but that the investigation would focus on

potential threats to current players only. They told me that they would not investigate past

abuses, such as mine, unless it impacted current player safety. They also promised that I

could have a copy of whatever report their internal investigation generated and that the

report would not be redacted. I felt uneasy about this meeting, so I followed up via email

asking for the report. They promised me a copy the report. A copy of the email exchange

with Mr. Robison setting out the above is attached to this affidavit as Exhibit “A”.

5. They also suggested that I get in touch with Sheldon Kennedy, which I did. I told

Mr. Kennedy about what happened to me. He said he would speak to the WHL and get

back to me. I did not hear back from Mr. Kennedy or from the WHL in the following days.

6. It is my impression that the investigation that Mr. Robison and Mr. Doerksen were

referring to in our calls and emails is the investigation they described publicly on June 26,

2020. I attach a CHL press release at Exhibit “B”.

7. As the days passed, I became more and more offended by the fact that the WHL

would not address the abuse I suffered in the early 1980s. I felt as if they did not care about

me and the others who played in the league who were abused. I outlined how common

such abuses were when I played in the WHL in my Original Affidavit and I explained this

to Mr. Robison and Mr. Doerksen. This was common knowledge when I was playing in

030

- 4 -

the WHL. I was astounded at how little regard they had for what impacted thousands of

players’ lives.

8. I decided to get in touch with Rick Westhead, a reporter at TSN/CTV, who had

been reporting on abuse in the CHL. I did an interview, which was aired on CTV national

news on June 25, 2020. I did not name names, but I told my story. I agreed to have my

name published on June 26, 2020. Mr. Westhead’s coverage is attached at Exhibit “C”.

9. After my interview aired, Mr. Robison emailed me on July 2, 2020 and told me

they would no longer involve me in the internal investigation. He told me to contact

proposed Class Counsel in this case. This email is attached at Exhibit “D”.

10. I felt that the WHL would only consider my allegations as long as they were able

to keep them secret. I felt that they were trying to control me and my story of abuse. Mr.

Robison’s email suggested that I could no longer access the unredacted independent

report, given my interview with Mr. Westhead. I am very interested to see the findings of

this independent report. Parents of current players ought to know whether the Defendants

are taking real steps to protect their children from the types of abuses I believe still take

place today.

11. Since I told my story last year, I have been blackballed by the hockey community.

I used to be a scout for various teams, including in the NHL. Not long after the CTV story

aired, I received communications from one NHL team saying they no longer needed my

services. Others simply stopped calling. One of my close friends advised me that another

of our old junior hockey buddies simply said “when did Brad turn gay” when the subject

of my interview came up in conversation. I feel as if I am alone on an island now, with

most of my peers turning on me for telling the world what everybody knew was happening.

12. After the CTV story aired, I received a threatening letter from an Alberta criminal

defence attorney, dated July 7, 2020. He accused me of making “Defamatory False

Accusations” against his client. He referred to my email communications with Mr.

Robison. I do not know how my communications with Mr. Robison made their way into

the hands of this lawyer or his client. This letter contained a threat that if I continue this

031

- 5 -

“defamatory conduct”, his client will commence legal proceedings against me. A copy of

this letter is attached at Exhibit “E”.

13. After receiving this letter, I knew that supporting this lawsuit was the right thing

to do, and that I cannot be silenced by threats.

14. I knew that there would be repercussions if I reported my abuse. Everybody knows

you will be blackballed if you say anything. If you do not toe the line in junior hockey,

you are made to be an outsider. Those are the unwritten rules.

15. I believe that by telling my story, others will realize they are not alone. I hope that

this class proceeding will help change the culture of junior hockey, and it will allow those

who I know suffered abuse to come forward. The pressure to stay quiet should not stop

people from telling their stories and I believe this case will allow for decades of secrets to

be revealed. I know that by telling my story, I have come a long way in healing. I hope

others will see it the same way.

16. I swear this affidavit in support of the motion for certification and for no other or

improper purpose

SWORN by Brad Hammett, via video-link

from the City of St. Albert, in the Province of

Alberta, before me in the City of Toronto, in

the Province of Ontario, on November __,

2021, in accordance with O. Reg. 431/20,

Administering Oath or Declaration Remotely.

BRAD HAMMETT

A Commissioner for taking Affidavits (or as may be)

NATHALIE GONDEK LSO #: 77660H

032

THIS IS EXHIBIT “A” REFERRED TO IN THE AFFIDAVIT OF BRAD HAMMETT SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THE

COVID-19 PANDEMIC FROM THE CITY OF ST. ALBERT, IN THEPROVINCE OF ALBERTA, TO THE CITY OF TORONTO, IN THE

PROVINCE OF ONTARIO, THIS _____TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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Great thank you much appreciated.

Brad

Sent from BKHammett

-------- Original message --------

From: Ron Robison < >

Date: 2020-06-24 4:16 PM (GMT-07:00)

To: Brad Hammett < >

Subject: Re: Brad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner

Richard Doerksen, Vice-President, Hockey

Brad

Thanks for your time today. I am in agreement with this and want to assure you it will be handled in this manner.

I will be in touch with you early next week.

Regards,

Ron

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

RON ROBISON | Commissioner

Western Hockey League

Father David Bauer Arena | 2424 University Drive NW | Calgary, AB, T2N 3Y9

Direct: 403.693.3033 | Fax: 403.693.3031

Email: | Website: www.whl.ca

On Jun 24, 2020, at 12:16 PM, Brad Hammett < > wrote:

Ron,

I wanted to thank you and Richard for taking the time to speak with me today regarding my allegations. I was hoping to get your commitment prior to speaking with the Security Network Group or the Head of WHL Security conducting the report confirming I will receive a full transcript and unredacted copy of the investigation report that I agreed to participate in. I believe considering the personal nature of the information this is a justifiable request. Hope you are in agreement.

Thank you Brad Hammett

From: "bkhammett" <bkhammett@shaw.ca> To: "Ron Robison" <robisonr@whl.ca> Cc: " Sent: Tuesday, June 23, 2020 3:00:32 PM Subject: Re: Brad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner Richard Doerksen, Vice-President, Hockey

That will be great, talk then.

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Brad

Sent from BKHammett

-------- Original message -------- From: Ron Robison < > Date: 2020-06-23 2:48 PM (GMT-07:00) To: Cc: Richard Doerksen < > Subject: Re: Brad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner Richard Doerksen, Vice-President, Hockey

Hi Brad

We appreciate how difficult this is for you and we look forward to speaking with you tomorrow.

Would 11:00 am tomorrow morning work for you? Richard Doerksen will be joining me on the call. We will call your cell phone.

Thanks

Ron

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

RON ROBISON | Commissioner

Western Hockey League

Father David Bauer Arena | 2424 University Drive NW | Calgary, AB, T2N 3Y9

Direct: 403.693.3033 | Fax: 403.693.3031

Email: | Website: www.whl.ca

On Jun 23, 2020, at 12:06 PM, wrote:

Ron

Thank you very much for responding, its very difficult speaking to this. I can be contacted anytime tomorrow at cell, I'm in St. Albert AB

Look forward to hearing from you Brad Hammett

Cell

Sent from BKHammett

-------- Original message -------- From: Ron Robison < > Date: 2020-06-23 9:20 AM (GMT-07:00) To: Cc: Richard Doerksen < > Subject: Fwd: Brtad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner Richard Doerksen, Vice-President, Hockey

Brad,

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This will acknowledge receipt of your email of June 20, 2020.

These are deeply disturbing allegations you have made of your experience in the WHL during the early 1980s. We take allegations of this nature very seriously and we would like to connect with you immediately to being our investigation into this matter.

The WHL is fully committed to providing a safe and positive environment for our players and we now have extensive prevention systems in place to ensure these type of situations do not occur. This includes a zero tolerance for any form of harassment or abuse.

Please let me know when you are available to discuss this matter and what would be the best number to reach you at.

Regards,

Ron

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct

file and location.

RON ROBISON | Commissioner

Western Hockey League

Father David Bauer Arena | 2424 University Drive NW | Calgary, AB, T2N 3Y9

Direct: 403.693.3033 | Fax: 403.693.3031

Email: | Website: www.whl.ca

-----Original Message----- From: Brad Hammett < > Sent: June 20, 2020 2:07 PM To: info@whl.ca Cc: Subject: Brtad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner Richard Doerksen, Vice-President, Hockey

Ron / Richard

My name is Brad Hammett, Im an Alumni Player in the AJHL, WHL, CHL, ACHL, AAHL, IHL, ACAC and I would like to ask you a question.

What would propel a rookie on a WHL team playing on the #1 line who lived, breathed and dreamed of playing in the NHL to get off a bus after 8 WHL games and return to his hometown team (St.Albert Saints in the AJHL) the year Gord Kluzak was on the team and went #1 overall when every NHL Scout in the world was watching every game?

I will tell you. Sexual and physical abuse I personally suffered in 1981-82 during my time with the WHL Billings Bighorns and 1982-83 with the WHL Nanaimo Islanders would be the answer. The abuse transformed me from a driven happy engaged young man and a solid NHL hockey prospect into a black mass of anger, untrust of people, self isolation and alcohol abuse. The recent CHL allegations of abuse triggerd anger in me and brought forward flashbacks and anguish.

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Let me state for the record I am not looking to join a lawsuit nor expose peoples names however, these events traumatized me and set me on a path of alcohol abuse, labelling me a quitter, bad act, alcoholic and off ice problem negatively effecting my career greatly. On the contrary I would like to offer my experiences and skill set to the WHL as a resource to speak with players/parents and possibly to investigate incidents of this and other types on behalf of the league.

I cannot stay silent any longer as the trauma of the abuse has stayed with me to this day and negatively effected my quality of life, trust in people and relationships even after my hockey career and being sober since 2002. I have not revealed the abuse to anyone including my wife of 25 years nor my two children in their twenties until today after speaking to her and then with a current WHL GM/ President/Mentor and Former Coach whom I greatly respect.

Throughout my 18 year career as a Nationally Certified (NCSO) in the Alberta Oil and Gas Industry as an owner/operator of my own company I have championed fair treatment of workers and accountability to the clients I represented in thousands of incident investigations, compliance issues and personal problems with a focus on improvement and goal of making people better. I consider my safety and investigation career a great accomplishment personally considering the abuse and trauma suffered in the WHL has never left me. I believe many things can be overcome through hard work and dedication but tolerating injustice can and never will be tolerated and I hope you take my communication seriously by immediate action. Many people are watching to see how and what the WHL/CHL does to address this sickening stain with meaningful action including myself and more importantly God. These young men and their parents trust you will watch over them and you cannot let them down, speaking from experience its difficult enough playing in the WHL talent wise, lots of sacrifies made by a lot of people including family, but its spiritually devastating to endure any type of sexual, mental or physical abuse from team mates whom you though were morally correct, nurturing and supportive human beings.

Let me tell you very clearly It truly rocks you to the core to discover otherwise as I can validate.

1. In 1981 while on a road trip I was attacked in the team hotel room by my two roommates / line mates, one is a current GM in the WHL the other a well named Hockey School Owner Operator and brother of a member of the Hockey Hall of Fame. The abuse occurred while I was unfolding the rookie cot, I was attacked and pinned down face first by the two assailants my hands at my side with one assailant kneeling on each of my shoulder with his crotch against the back of my head and the second assailant sitting on my upper back. I was pinned helpless and unable to move, my face was pushed into the mattress the only way to breathe was to move my head from side to side to get a gasp of air. The first assailant sitting on my shoulders removed his penis from his pants and proceeded to slap his penis off the side of my face when I attempted to get air while both assailants laughed saying "not so tough now hey rookie". When my parents show up to watch the game in Lethbridge I put my bag in the trunk and said Im leaving the team much to their disbelief and disappointment never telling anyone of the incident until today when

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I spoke to a former Coach and WHL President/GM whom I respect greatly about the abuse.

2. In 1982 while boarding in an upper area of the pool in a bunk style training camp set up I walked in on the same two assailants making several rookies strip naked, a line had been placed on the floor with tape and a hockey lace was attached to each rookies penis and they were being forced to pull the other rover the tape line. I immediately intervened with physical force against the assailants and stated firmly" this shit stops now and Im not pinned down this time".

3. In 1982 as a member of the WHL Nanaimo Islanders the same two assailants along with two other assailants attacked me from behind while coming out of the dressing room shower after practice in retaliation to my intervention of their abuse of the rookies a few days prior. There was no one else in the room we had stayed out late for extra conditioning after practice. The assailants immediately put a sock over my head from behind, taped it around my neck and punched my repeatedly in the ribs and thighs until I fell to the ground. Once beaten to the ground my arms were held out to the side by two assailants standing on them and I was taped to a hockey stick behind my head crucifixion style. I was then dragged across the room by the hockey stick into the shower where the water was turned on scalding hot, a hockey lace was put on my penis and a coat rack was dragged into the shower, the lace was thrown over the rack and the other end was attached to my ankle. I was left in the shower for over an hour until the tape was soft enough to break free, all the while as my leg lowered it pulled my penis to the point of bleeding and tearing of the skin.

4. I was voted Captain of the WHL Nanaimo Islanders that season unfortunately I tore my ACL after 30 games and had to return home for season ending surgery. When I returned to the team for re hab the first time on the ice in sweats helmet gloves only up and down the boards the two same assailants along with another assailant fired pucks at my injured knee from across the ice. When I stopped to confront them I was sucker punched by a third assailant at their direction from the side and helplessly fell to the ice as my knee had no strength to support my weight let alone fight. My tooth was knocked out and my eye swollen shut, immediately teammates came to my defense. The two assailants who orcastrated the assult were traded to the Medicine Hat Tigers shortly thereafter. The franchise moved to WHL New Westminster Bruins the next season as did I where I was vote Assistant Captain but the damage was done, my reputation destroyed and the alcohol abuse intensified as a means of coping, there was simply no one to talk too, you were considered weak and a problem in the age of tape it up, if you can move you can play, or if you make problems youre gone.

I hope you see the considerable abuse I sustained while in the WHL and appreciate the incidents impact on my life as considerable. In looking back on the WHL the 1980's lots of things were not spoken to and things were handled differently for sure but abuse and assult is abuse and assult. It cannot be allowed to continue and Im counting on you to do the right thing as leaders, parents and human beings.

Thank you Brad Hammett St.Albert, Alberta

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THIS IS EXHIBIT “B” REFERRED TO IN THE AFFIDAVIT OF BRAD HAMMETT SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THE

COVID-19 PANDEMIC FROM THE CITY OF ST. ALBERT, IN THEPROVINCE OF ALBERTA, TO THE CITY OF TORONTO, IN THE

PROVINCE OF ONTARIO, THIS _____TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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THIS IS EXHIBIT “C” REFERRED TO IN THE AFFIDAVIT OF BRAD HAMMETT SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THE

COVID-19 PANDEMIC FROM THE CITY OF ST. ALBERT, IN THEPROVINCE OF ALBERTA, TO THE CITY OF TORONTO, IN THE

PROVINCE OF ONTARIO, THIS _____TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

042

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THIS IS EXHIBIT “D” REFERRED TO IN THE AFFIDAVIT OF BRAD HAMMETT SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THE

COVID-19 PANDEMIC FROM THE CITY OF ST. ALBERT, IN THEPROVINCE OF ALBERTA, TO THE CITY OF TORONTO, IN THE

PROVINCE OF ONTARIO, THIS _____TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

046

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Nathalie Gondek

From: Ron Robison < >

Sent: July 2, 2020 7:21 PM

To:

Cc: Richard Doerksen

Subject: WHL Investigation

Brad,

During our telephone conversation on Wednesday June 24, it was agreed the WHL would conduct an investigation into the allegations you registered with the WHL Office in your email of June 20. You indicated during our call that you would cooperate fully with the investigation and had no interest in participating in the pending CHL class action lawsuit. We also exchanged emails on June 24 at which time it was agreed we would provide you with a full transcript and redacted copy of the investigation report before it was released.

I was subsequently notified by CTV reporter Rick Westhead that you had given him permission to quote you on the record, identify the WHL teams and seasons you played as well as the names of the alleged abusers. Mr. Westhead also informed me that you had decided to join the proposed class action. All of these details, with the exception of the names of the alleged abusers and your decision to join the class action, were contained in a CTV National News story by Rick Westhead on June 26.

Under the circumstances, I would ask that you contact the counsel representing the plaintiffs in the class action and then advise the WHL formally if you will participate in a WHL investigation. That investigation will be restricted to determining whether the allegations you raise pose any risk to current players.

Once we have received confirmation of your position, we will be positioned to determine whether we will proceed with our investigation.

Your earliest response would be appreciated.

Regards

Ron

RON ROBISON | Commissioner Western Hockey League Father David Bauer Arena | 2424 University Drive NW | Calgary, AB, T2N 3Y9Direct: 403.693.3033 | Fax: 403.693.3031Email: | Website: www.whl.caFacebook: WHLHockey | Twitter : TheWHL

From: bkhammett < >

Sent: Wednesday, June 24, 2020 4:22 PM

To: Ron Robison < >

Cc: bkhammett@shaw.ca < >

Subject: Re: Brad Hammett Sexual and Physical Abuse of former WHL Player Attention: Ron Robison, Commissioner

Richard Doerksen, Vice-President, Hockey

047

THIS IS EXHIBIT “E” REFERRED TO IN THE AFFIDAVIT OF BRAD HAMMETT SWORN BEFORE ME BY VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THE

COVID-19 PANDEMIC FROM THE CITY OF ST. ALBERT, IN THEPROVINCE OF ALBERTA, TO THE CITY OF TORONTO, IN THE

PROVINCE OF ONTARIO, THIS _____TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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051

Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR

HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD., KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS

HOCKEY CLUB INC., 2325224 ONTARIO INC. o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY

BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY ACADEMY LTD., OTTAWA 67'S LIMITED PARTNERSHIP c.o.b. OTTAWA

67's HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY

WOLVES HOCKEY CLUB LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as

BRANDON WHEAT KINGS, BRANDON WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY

SPORTS AND ENTERTAINMENT CORPORATION, EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB,

INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS

& ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER

JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA

ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT TIGERS, SWIFT CURRENT TIER 1

FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS & ENTERTAINMENT INC. o/a

WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC. WARRIORS o/a

MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB,

052

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649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE

TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE

BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES OLYMPIQUES DE GATINEAU INC.,

HALIFAX MOOSEHEADS HOCKEY CLUB INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA

INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-

NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS, LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN

MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a CATARACTES SHAWNIGAN, CLUB DE HOCKEY

JUNIOR MAJEUR VAL D’OR INC. o/a VAL D'OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY LE PHOENIX, 9264-8849 QUÉBEC

INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS HOCKEY c.o.b. FLINT

FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY

AMERICANS HOCKEY LLC, and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

AFFIDAVIT OF JAY JOHNSON (Sworn November 29, 2021)

I, JAY JOHNSON, of the City of Winnipeg, Province of Manitoba MAKE OATH

AND SAY:

1. I have been retained by Koskie Minsky LLP to provide my unbiased expert opinion

in support of the certification motion in this matter.

2. A copy of my reply report is attached to this Affidavit as Exhibit "A".

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3. A copy of my updated curriculum vitae is attached to this Affidavit as Exhibit

"B".

4. My Acknowledgement of Expert's Duty is attached to this Affidavit as Exhibit

"C".

SWORN via video-link from the City of

Winnipeg, in the Province of Manitoba,

before me in the City of Toronto, in the

Province of Ontario, on November 29, 2021,

in accordance with O. Reg. 431/20,

Administering Oath or Declaration Remotely.

JAY JOHNSON

A Commissioner for taking Affidavits (or as may be)

Sue Tan LSO# 74826A

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THIS IS EXHIBIT “A” REFERRED TO IN THE AFFIDAVIT OF JAY JOHNSON SWORN BEFORE ME BY VIDEO-

CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF WINNIPEG, IN PROVINCE OF

MANITOBA, TO THE CITY OF TORONTO, IN THE PROVINCE OFONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

SUE TAN

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CarcilloetalvCHL

EXPERT REPORT OF DR. JAY JOHNSON FOR CERTIFICATION (REPLY)

Introduction

I am a Professor at the University of Manitoba, and am recognized in my academic field over

the past 25 years as an expert in the area of sport hazing, initiations and rites of passage. I have

been retained by the law firm of Koskie Minsky LLP to prepare this response to the Affidavit of

Paul Dennis, sworn November 1, 2021 for the purpose of the certification motion in the Carcillo

et. al. v. Canadian Hockey League et. al. matter. I have been asked to comment on:

1) The affidavit submitted by Paul Dennis which addresses his experience in a variety of roles

in Junior and Professional hockey settings up to and including his current role as Head of

the OHL’s Player Development Program;

2) His academic perspective-as outlined in the attached 5-page article titled Harassment in

Sport: Implications for coaches regarding sexual abuse and hazing. (Journal CAPHERD

64 2 p. 14-19, summer 1998);

I have been provided with the Affidavit completed by Paul Dennis. In preparing this report, I have

relied on my academic, methodological (quantitative and qualitative methods) field research

experience, including my experience conducting academic research specifically focused on hazing

in sport in Canada since 1996 and an extensive and thorough review of academic and secondary

(media sources) related to hazing in sport, many of which I have authored or co-authored in

preparing this comment. The list of studies, collaborations, academic papers,

and media reports attached as (Appendix A) have focused on the narratives and experiences of

both male and female athletes, former athletes, coaches and athletic or sport directors whose hazing

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experiences spanned across the decades of 1960’s, 70’s, 80’s, 90’s 00’s, and 10’s to the present

day.

Commentary on Dr. Dennis' observations and experience

Dr. Dennis appears to use the term "abusive" or "ritual" hazing to parse what he sees as

problematic (sexually based) and other forms of hazing (non-problematic) in describing his

observations in his multiple capacities within the sport of hockey and specific to the OHL and

NHL. It is not surprising that he is indicating a personal history of not having witnessed “abusive”

hazing directly and only hearing about limited examples on other teams. It is also unsurprising that

he describes individual athletes not approaching him in his leadership capacities, despite his best

intentions of developing an environment where he feels athletes would have felt empowered to

approach him with incidents of “abusive” hazing. These revelations must be understood within the

power dynamic of junior hockey.

In all of the professional capacities that Paul Dennis described in his affidavit, he was and

continues to be in a position of power and authority. This includes his current paid position as

head of the Ontario Hockey League’s Player Development Program, where he describes being an

integral component of athletes' well-being and inclusion, within and into other hockey cultures,

such as the transition he describes from junior to professional hockey.

It is not an uncommon verse to hear described in the literature that individuals in these positions

of power, such as a coach, a therapist, or someone in the administration and running of an

organization, is not only protected from knowledge, but is usually the last to hear of incidents of

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abuse. This is because people who are victimized face further personal repercussions and being

ostracized, marginalized and shunned from the hockey community. As I described in my original

report, I believe junior hockey in Canada is an archetypal example of such a system. Silence

operates within these cultures precisely for this reason, as players stand to risk the abovementioned

repercussions when outing practices on teams such as hazing (see Appendix A and most recently

the public cases of Kyle Beach and Akim Aliu to see examples of the pervasiveness of the cultural

complicity within hockey).

Much of the literature I list in "Appendix A" also show how within hockey, and particular junior

hockey, the propensity is to continue to frame the “problem” as one or two bad actors that are

being acted on and highlight those instances as evidence of dealing with the problem, in

conjunction with an eye towards future systemic vigilance in weeding out such individuals.

I have highlighted the term "abusive hazing" as I believe Dr. Dennis is using this to describe

hazing with sexual dimensions to describe both his direct and indirect observations and

experiences with hazing in general. He uses this term to describe his academic understanding as

well. I believe that Dr. Dennis is attempting to delineate is acceptable and what is not acceptable

in terms of hazing in junior hockey. I believe this is an artificial distinction, and in practice, it does

not provide adequate protection to children who have moved away from home to play junior

hockey.

Dr. Dennis usees the term "abusive hazing" to refer to hazing with sexual dimensions. He then

describes his direct and indirect observations and experiences with hazing in general.

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Dr. Dennis speaks to attempting to create an environment that is inclusive, free from harassment,

discrimination and abuse, and provides specific examples of unacceptable hazing he has heard

about, such as the "hotbox". He indicates that under his watch, none of his teams took part in such

abusive hazing. He describes incidents such as carrying equipment, cleaning up after, and doing

tasks for veteran players, dressing up as women, etc. as being non-abusive hazing.

In my opinion, Dr. Dennis is attempting to create a false distinction between what he personally

views as "acceptable" hazing, such as pressuring underage players to wear womens' clothing in

public, and what is "unacceptable", such as what Mr. Carcillo and Mr. Taylor describe in their

Statement of Claim. I do not think this distinction is helpful in the context of junior hockey,

because I believe that Dr. Dennis's "acceptable" examples are designed to humiliate, and are rooted

in misogyny, power, hierarchy and conformity. When considered in the cultural context of junior

hockey, I do not believe that these practices are "acceptable". In the many first-hand descriptions

of abuse in junior hockey I have heard from current or former players, the hazing Dr. Dennis

describes as "acceptable" almost always take place alongside the types of hazing Dr. Dennis would

describe as "unacceptable". Put bluntly, I do not believe it is possible to provide players with

authority to "haze" in the "acceptable" manner that Dr. Dennis describes in junior hockey, without

behaviours that Dr. Dennis would describe as "unacceptable" often being the result.

Dr. Dennis could certainly be described as a long-standing insider within the culture of elite and

specifically, junior and professional hockey. While there is the exceptional coach, or administrator

who has been proactive in redefining the culture surrounding hazing on their team, they are

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typically the anomaly. As described in the academic literature, most authority figures have taken

a distanced approach (ie, a "don’t ask, don’t tell" approach to hazing over the years) often not

knowing what their teams are engaged with or even what parameters define what is acceptable and

what is not with regards to a team’s conduct. Often, when engaged in discussion, individuals such

as coaches, administrators and players do not realize that when their teams were doing something

described by them as being innocuous, such as dressing their first year players up as women, or

forcing them to consume massive amounts of alcohol (something not described by Paul Dennis in

his affidavit), that those activities are in fact unacceptable hazing, and are rooted in the same

abusive elements that Dr. Dennis is using to define hazing here. His testimony here is in line with

the perceptions of many of the coaches, administrators and athletes that I have personally

interviewed over the years in my capacity as a researcher and academic. It is a limited view in

terms of recognizing his position of power in the structure of hockey and fails to recognize the

cultural dimensions of hazing practices in general and hockey specifically.

Dr. Dennis's Article

Dr. Dennis described himself as a former part-time professor. As a currently employed tenured

Professor at a University in Canada, I am unfamiliar with this term or position. A professor’s work

portfolio in general revolves around 3 components: teaching, research and administrative service.

I believe that he was a sessional instructor, or perhaps limited term appointment where he taught

some academic courses in a university, as I was hard pressed to find much in the way of his

academic work that he referenced in his affidavit. I did find that he co-authored a paper based on

another person's research and he did author a chapter in a textbook that was not peer reviewed. I

could not find any academic work authored by Dr. Dennis specific to research on hazing in sport

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or hazing in hockey. The article he provides is brief compared to most peer-reviewed academic

articles. The CAPHER journal (where this article was published) is one that is designed as an

informational portal for professionals such as teachers, coaches etc. and in this case, the article

was a textual analysis citing a few media cases at the time. The article did not rely upon or reference

any academic research specific to hazing or hazing in sport, and can be characterized as more of

an opinion piece. While there are certainly some suggestions in the article which I feel hold merit

for organizations to consider or implement, such as vigilance in screening for past criminal

behaviours or convictions, the article is centred on the premise that the cases were perpetrated by

individual actors, and his paper is devoid of any mention of structural, organizational or cultural

issues that allow problematic hazing and sexual abuse to happen in the context of hockey. The

article is not premised on research, certainly none conducted by Dr. Dennis, and in my view does

little to advance our understanding of hazing in junior hockey, beyond the oft-repeated and

inappropriate suggestion for organizations, parents and players to be vigilant in weeding out

potential “bad apples” who may be looking to prey on athletes. As I have stately previously in the

extensive report submitted previously on this case, an up to date reference list of current academic

and media reports of hazing in sport as Appendix A, there is ample academic research beyond my

own, grounded in the anonymous narratives and experiences of athletes (current and former),

coaches, athletic directors and administrators and others describing hazing in sport and specifically

junior hockey, which speaks to the historical and continued pervasiveness of hazing in junior

hockey, including but not limited to the complexities of cultural dimensions of hazing and how

and why it operates. This body of work goes well beyond the narrow description offered in Dr.

Dennis's affidavit.

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This constitutes my brief overview and response to the information provided in Dr. Paul Dennis's

affidavit.

Sincerely,

Dr. jay johnson

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THIS IS EXHIBIT “B” REFERRED TO IN THE AFFIDAVIT OF JAY JOHNSON SWORN BEFORE ME BY VIDEO-

CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF WINNIPEG, IN PROVINCE OF

MANITOBA, TO THE CITY OF TORONTO, IN THE PROVINCE OFONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

SUE TAN

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CURRICULUM VITAE

PROFESSOR FACULTY OF KINESIOLOGY AND RECREATION MANAGEMENT, UNIVERSITY OF MANITOBA, 113 Frank Kennedy Centre, Winnipeg, Manitoba, R3T 2N2 204-474-8996 EMAIL: jay.johnson@umanitoba.ca EDUCATION Post Doctorate, McMaster University, Department of Psychology, Neuroscience &

Behaviour, Hamilton, Ontario; 2006 "Parents’, the Unacknowledged Victims of Bullying and Harassment” Ph.D., University of Toronto, Toronto, Ontario; 2006

Education, Sociology and Equity Studies Dissertation: “An Examination of Alternative Orientations and Their Effect on Initiations in Varsity Culture” Supervisor: Paul Olson

M.Sc., University of Toronto, Toronto, Ontario; 2000

Exercise Science, Faculty of Physical Education and Health Thesis: “Sport Hazing Experiences in the Context of Anti-Hazing Policies --The Case of Two Southern Ontario Universities” Sociology of Sport Supervisor: Dr. Peter Donnelly

B.ED. University of Toronto, Toronto, Ontario; 1994

Faculty of Education, Intermediate/Senior Panel, Physical Education and Individual and Society, Special Education (UWO)

B.A., University of Guelph, Guelph, Ontario; 1993 Specialized Honours, Sociology and Anthropology Minor Human Kinetics

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RESEARCH AND SCHOLARSHIP PRODUCTIVITY PEER-REVIEWED PUBLICATIONS (Published) Butryn, T., Masucci, M., & j. johnson. (2020). The show must go on: The strategy and spectacle of Dana White’s efforts to promote UFC 249 during the coronavirus pandemic. International Journal of Sport Communication. http://dx.doi.org/10.1123/ijsc.2020-0240 johnson, j. & A. E. Ali. (2020). Paddling for reconciliation: A decolonial approach to land-based education amongst Manitoba Indigenous youth. Diaspora, Indigenous, and Minority Education, 14(4), p. 205-219. https://doi.org/10.1080/15595692.2019.1669015 johnson, j., Holman, M. & M. Havey. (2019). Transforming team bonding to a safe and positive experience©: A toolkit for hazing education: Understanding, prevention & transformation. Physical and Health Education Journal, 83(4), p.1-37. Chin, J., johnson, j., Holman, M. & M. A. Signer-Kroeker. (2019). From the bottom of a bottle: A sociological examination of the use of alcohol in varsity sport hazing. International Review for the Sociology of Sport, p. 1-18. https://doi.org/10.1177/1012690219861607 Chin, J. W., Masucci, M. & j. johnson. (2019). Keep it rolling: Examining the San José Bike Party with methods on the move. Qualitative Research in Sport, Exercise and Health. https://doi.org/10.1080/2159676X.2019.1673471 Masucci, M., Butryn, T. & j. johnson. (2019). Knowledge and perceptions of doping practices and anti-doping education among elite North American female triathletes. Performance Enhancement and Health. https://doi.org/10.1016/j.peh.2019.02.001 johnson, j. & A. E. Ali. (2018). Ecological modernization and the 2014 NHL sustainability report. Sociology of Sport Journal, 35(1), p.49-57. johnson j., Masucci, M.A. & M. A. Signer. (2018). Everything looks better from the seat of a bike”: A qualitative exploration of the San José Bike Party. Leisure/Loisir Journal, 42(2), p.163-184. johnson, j., Holman, M., Chin, J., Guerrero, M. & M.A. Signer. (2018). An examination of hazing in Canadian intercollegiate sports. Journal of Clinical Sport Psychology, 12(2), p. 144-159. doi: 10.1123/jcsp.2016-0040 johnson, j. & A. E. Ali. (2017). Skating on thin ice? An interrogation of Canada’s melting pastime. World Leisure Journal, 59(4), p. 259-271.

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Kim, J. & j. johnson. (2017). Mini U Brochures: Advertising social exclusion at a post-secondary institution, Canada? European Journal of Sustainable Development, 6(1), p.103-122. johnson, j. & J. W. Chin. (2016). Seeking new glory (d)haze: A qualitative examination of adventure-based, team orientation rituals as an alternative to traditional sport hazing for athletes and coaches. International Journal of Sports Science and Coaching, 11(3), p.327-341. Safai, P., johnson, j. & J. Bryans. (2016). The Absence of Resistance Training? Exploring the politics of health in high performance youth triathlon. Sociology of Sport Journal, 33(4), p.269-281. johnson, j. & A.E. Ali. (2016). The Climate Activist? The inverted quarantine and individuals protecting themselves from environmental "risk" through the consumption of products. In F. Wherry and J. B. Schor (Eds.), The SAGE Encyclopedia of Economics and Society. (p. 389-392). Sage Publishing. johnson, j. & J. W. Chin. (2015). Hazing rites/rights: using outdoor- and adventure education-based orientation to effect positive change for first-year athletes. Journal of Adventure Education and Outdoor Learning, 16(1), p.16-30. Holman, M. & j. johnson. (2015). Moving from awareness towards prevention: A case study of varsity athletic hazing as a guide for administrators. Physical and Health Education Journal, 81(2), p.1-29. Moola, F., johnson, j., Lay, J., Krygsman, S. & G. Faulkner. (2015). The Heartbeat of Hamilton: Reflections on the methodological process of exploring Hamilton youths’ environmental perceptions. International Journal of Qualitative Methods, (14) 4. p. 1-14. DOI: 10.1177/1609406915611560. johnson, j., Butryn, T. & M. Masucci. (2013). A qualitative examination of doping knowledge among elite female triathletes. Sport in Society, Cultures, Commerce, Media, Politics, 16(5), p. 654-671. Butryn, T., johnson, j. & M. Masucci. (June, 2012). A qualitative examination of knowledge of doping and anti-doping education among elite US and Canadian female triathletes. Report prepared for the World Anti--Doping Agency (WADA), June, 2012, p. 1-33. http://www.wada-ama.org/en/ Eliopulos, L., & j. johnson. (2012). Inside the vortex of sport celebrification: A textual analysis of Jessica Simpson, Tony Romo, and traditionally constructed gender roles. International Journal of Sport Communication, 5(2), p. 210-230. Chin, J. W. & j. johnson. (2011). Making the team: Threats to health and wellness within sport hazing cultures. The International Journal of Health, Wellness and Society, 1(2), p. 29-38.

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johnson, j. (2011). Through the liminal: A comparative analysis of communitas and rites of passage in sport hazing and initiations. Canadian Journal of Sociology, 36(3), p. 199- 226. Holman, M., johnson, j. & M. K. Lucier. (2011). Sticks and stones: The multifarious effects of body-based harassment on young girls’ healthy lifestyle choices. Sport, Education and Society, 16(3), p. 1-23. johnson j. & M. A. Masucci. (2009). No final victories: 40 years on the frontlines of race, sport, and culture. An interview with scholar/activist Dr. Harry Edwards. Journal for the Study of Sports and Athletics in Education, 3 (2), p. 233-251. johnson, j. (2009). From the sidelines: The role of the coach in effecting team unity and cohesion. The Journal of Coaching Education, 2 (1), p. 1-28. johnson, j. & M. Holman. (2009). Gender and hazing: The same but different. The Journal of Physical Education, Recreation & Dance, 80 (3), p. 6-10. johnson, j. & Holman, M. (book) (August, 2004) (Eds). Making the Team: Inside the World of Sport Hazing and Initiations. Canadian Scholars’ Press. johnson, j. (2002). Are sisters doing it for themselves?: An analysis of gender and the sport initiation. Journal of Canadian Woman Studies/Les Cahiers de la Femme, 21, (3). johnson, j. (2002). Taking it like a man: A Re-examining the power structure in sport initiations. Journal of Culture and Tradition, (23), p. 10-31. BOOK CHAPTERS johnson, j., Butryn, T., & M. Masucci. (2021 (accepted). An unholy Triumvirate: Donald Trump, Dana White and the UFC in the age of the Pandemic. The Sociology of Sport and Physical Culture in Global Pandemic: Critical Diffractions. Edited by D. L. Andrews, H. Thorpe & J. I. Newman. Butryn, T., johnson, j. & M. Masucci. (2021). A "notorious" spectacle: Reading Conor McGregor through a narrative lens. In, The Circus Is in Town: Sport, Celebrity, and Spectacle. Edited by L. D. Alexander & J. N. Rosen (Eds.). University of Mississippi Press. Ali, A. E. & j. johnson. (2019). Sustainability, greenwashing, and sport environmentalism. In, The Business and Culture of Sport. Edited by J. Maguire, M. Falcous & K. Liston (Eds.). Macmillan Reference USA. johnson, j. & M. Holman. (2019). A model for success: A case study for managing varsity athletic hazing as a guide for administrators. Hazingprevention.org.

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johnson, j. & A. E. Ali. (2018). Sustainability, greenwashing, and the light green approach to sport environmentalism: An introduction to “sustainability”. In Handbook of Sport and the Environment. Edited by B. P. McCullough & T. Kellison (Eds.). Routledge International Publisher. johnson, j. (2015). Dying to make the team: A case study examining the benefits for athletic teams in using Outdoor Adventure Education practices in place of traditional hazing. In Adventure Programming and Travel for the 21st Century. Edited by R. Black & K. Bricker (Eds.), Venture Publishing, USA. johnson, j. (2007). Sport and the culture of hazing. Berkshire Encyclopedia of Extreme Sport. Edited by D. Booth & H. Thorpe (Eds.), Berkshire publishing, p.132139. johnson, j. & M. Holman. (2004). Making the Team: Inside the World of Sport Initiations and Hazing. Canadian Scholars Press. johnson, j. & P. Donnelly. (2004). In their own words: Athletic administrators, coaches, and athletes at two universities discuss hazing policy initiatives. In Making the Team: Inside the World of Sport Initiations and Hazing. Edited by j. johnson & M. Holman (Eds.), Canadian Scholars Press. johnson, j. & P. Miller. (2004). Changing the initiation ceremony. In Making the Team: Inside the World of Sport Initiations and Hazing. Edited by j. johnson & M. Holman, Canadian Scholars Press. johnson, j. & B. Trota. (2004). Introduction: A brief history of hazing. In Making the Team: Inside the World of Sport Initiations and Hazing. Edited by j. johnson & M. Holman, Canadian Scholars Press. PROFESSIONAL REPORTS/NON-REFEREED johnson, j. & M. Holman (December 7, 2020). CHL Expert Hazing Report (60 pages) of johnson and Holman for the Law Firm of Koskie Minsky LLP in support of the certification motion in the Carcillo v. CHL et al matter. johnson, j. & M. Holman (January 22, 2019). Changing the culture of hazing in Canada. sircuit.ca/changing-the-culture-of-hazing-in-canada Sport Information Resource Centre (SIRCuit). johnson, j., M. Holman & M. Havey. (2018). Transforming team bonding to a safe and positive experience© A toolkit for hazing education: Understanding, prevention & transformation. This document serves as a facilitator’s guide. It provides content to assist leaders when delivering a workshop or other educational format on Transforming team bonding to a safe and positive experience©. Material provided includes the powerpoint slides as a tool to guide lecture and discussion as well as other supportive strategies to

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move towards the prevention of hazing and the development of alternative bonding activities. Butryn, T., johnson, j. & M. Masucci. (June, 2012). A qualitative examination of knowledge of doping and anti-doping education among elite US and Canadian female triathletes. Report prepared for the World Anti--Doping Agency (WADA), June, 2012, p. 1-33. http://www.wada-ama.org/en/ johnson, j. (2007). NCAA handbook on Hazing, website link to alternatives to hazing. johnson, j. (2002). Program Evaluation of T.R.O.O.P. (The Toronto Recreational Outreach Out-tripping Program). The effectiveness of partnering at-risk youth and the police for wilderness education. Report prepared for LaMarsh Centre Child/Youth Violence Research Centre for Violence and Conflict Resolution, York University. johnson, j. (2001). Program Evaluation of the Orientation Program for Varsity Teams. Report prepared for the Faculty of Physical Education and Health as a follow-up to their orientation program for all varsity athletes. johnson, j. (2000). Program Evaluation of the Orientation Program for Varsity Teams. Report prepared for the Faculty of Physical Education and Health as a follow-up to their orientation program for all varsity athletes. johnson, j. & P.S. Miller. (2000). Student-Athlete Handbook. Handbook prepared for the Faculty of Physical Education and Health, University of Toronto. johnson, j. & P.S. Miller. (1999). Student-Athlete Handbook. Handbook prepared for the Faculty of Physical Education and Health, University of Toronto. johnson, j. & P.S. Miller. (1998). Handbook on Orientation and Transition for Students at the University of Toronto. Handbook prepared for the Faculty of Physical Education and Health, University of Toronto.

MANUSCRIPTS UNDER REVIEW johnson, j. Masucci, M. & J. Chin. A social movement: Exploring the “politics” of bicycle activism in the San José Bike Party. Butryn, T., j. johnson & M. Masucci. Getting into the weeds: An ethnographic content analysis of marijuana and cannabidiol (CBD) use among NFL and UFC professional athletes. MANUSCRIPTS PREPARAING FOR SUBMISSION johnson, j. Okwiinowag Ojiimaan: The impact of a traditional land based educational experience on Indigenous and Métis university mentors.

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johnson, j. & B. Langlais. Mino-bimaadiziwin Through Indigenous Mentorship: The Photovoice Project. johnson, j., Chin, J., Holman, M. & M. A. Signer-Kroeker. Gender revisited: A National examination of the gendered practices in varsity sport hazing. johnson, j. & A, Ali. In conversation with “nature”: Placing a decolonizing lens on land-based education for transformative possibilities. johnson, j. (book for publication). Hazed and confused: Towards a theoretical understanding of sport hazing and initiation. RESEARCH GRANTS, HONOURS & AWARDS (2021-2023). Wilson, B., Bundon, A., Norman, M. (PIs), johnson, j., et.al., collaborators. ‘Mobilizing Sport and Sustainability’. Grants for Catalyzing Research Clusters (GCRC), University of British Columbia. The Mobilizing Sport & Sustainability Collective, in association with UBC’s Centre for Sport and Sustainability (CSS). ($100, 000). Funded. (2020-2022). Yi, K.J., johnson, j. (Co-I), Leclaire, L., & C. Glazebrook. The Good, the bad, and the ugly of community service learning: Educators' lived stories. University Collaborative Research Program (UCRP). ($24, 670). Funded. (2020-2023). johnson, j., (PI) Johansen, K., Holman, M., Chin, J., & Haras, K. Re-creating cultural traditions to welcome new athletes: Using experiential education to change harmful hazing practices for high school and varsity student-athletes. Social Sciences and Humanities Research Council-SSHRC Insight Grant. ($99, 630). Submitting March, 2020. (2020-2023). Henhawk, D.(PI), johnson, j. (PI) & B. Rice (Co-I). Indigenous land based education: Loss, renewal and reconciliation. Social Sciences and Humanities Research Council-SSHRC Insight Grant. ($83, 700). Submitting June, 2021. (2020-2025). Passmore, S. (PI), Glazebrook, C. (Co-I), Stout, J. (Co-I), Hill, M. (C), Maiers, M. (C), Malone, Q. (C), Sargent, S. (C), Van Winkle, (C), & j. johnson, (KU). Patient experience and outcomes associated with cannabis as an intervention for chronic low back pain with comorbid anxiety. Canadian Institutes of Health Research (CIHR), Team Grant: Cannabis Research in Priority Areas. 5 years, ($1 500 000). Submitting, Fall, 2021. (2019-2024) McGavock, J. (PI), Halas, J., (PI), j. johnson (Co-I) & et al. Deepening our roots of living in a good way. The Indigenous Youth Mentorship Program. Canadian Institutes of Health Research (CIHR), Team Grant: Pathways to Health Equity for

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Indigenous People-Implementation Research Team Grant ($1 500 000). CIHR-Pathways 3 Grant-funded. (2019-2024) McGavock, J. (PI), Halas, J., (PI), et al., & j. johnson (Co-I). Diabetes Canada – Matching funds, ($250 000). Funded. (2015-2019) McGavock, J. (PI), Halas, J., (PI), Johnson, A., (PI), McRae, H., (PI), j. johnson (Co-I), et al. Aboriginal youth mentorship program in northern first nations communities. Canadian Institutes of Health Research (CIHR), Team Grant: Pathways (1 and 2) to Health Equity for Aboriginal People-Implementation Research Team Grant ($1 513 200). CIHR Funded. (2014-2018) johnson, j., (PI) M. Holman, Allan, E., M. Madden & J. Chin. Transforming the Canadian sport culture: A National study of gender, race, sexuality and violence in sport hazing as barriers to sport participation. Social Sciences and Humanities Research Council of Canada-Sport Participation Research Initiative ($138, 955). SSHRC Funded. (2016) johnson, j., & M. Holman, Women’s Campus Safety Grant, ($3600). Funded. (2015) Dean’s Excellence in Teaching Award-recipient. Faculty of Kinesiology and Recreation Management. (2014/2015) Norman, M., & j. johnson. University Grants Research Program (UGRP), 1 year. “Looking back before moving forward: An oral history of the physical cultures of Sandy Bay First Nation" ($7060). Funded. (Fall, 2014) johnson, j., Ethics Research Fellowship, Centre for Professional and Applied Ethics, University of Manitoba ($5000). Funded. (2013) johnson, j., University Grants Research Program (URGP), 1 year. A qualitative PhotoVoice community involvement research study examining aboriginal youth (dis) engagement with activity spaces” ($6961). Funded. (2010-12) Butryn, T., j. johnson & M. Masucci, a two year, grant from the World Anti Doping Agency (WADA). This study was a qualitative examination of knowledge of doping, and motivations and/or deterrents to dope, among American and Canadian elite U-23 female triathletes. ($29 000). Funded.

(2008-09) johnson j., & P. Safai, Investigation grant ($2700) York University, Toronto, Canada. Preliminary investigation in the culture of junior triathlete culture. Funded.

(2008-09) johnson, j., (Co-I) with Dr. M. Holman. Effects of body-based harassment on girls’ body image and participation in physical activity. ($7,760) Health Research Centre for the Study of Violence against Women Faculty Research Grant. Funded.

(2006) johnson, j., Postdoc, Psychology Department, McMaster University. Children,

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parents and bullying in schools and in sport. ($31,500). SSHRC funded.

(2003) johnson, j., Researcher, LaMarsh Centre Child/Youth Violence Research Support (LaMarsh Centre for Research on Violence and Conflict Resolution), York University. A pilot research projects which evaluates the effectiveness of T.R.O.O.P. (The Toronto Recreational Outreach Outtripping Program), which is a city program which brings together at-risk, inner city youth and the police for a five-day canoe trip designed to enhance positive relationships between the two and develop leadership and lifeskills for the participants. ($5000.00). Funded, York University. (2001) johnson, j., Consultant, Research Organizer and developer of the Varsity Orientation Program, Faculty of Physical Education and Health, University of Toronto. Responsible for the implementation and facilitation of alternative orientation programs which de-emphasize traditional hazing practices and focus on inclusion. Camp New Moon, Seneca College, 700 varsity athletes ($4000.00). Funded, University of Toronto. (2000-2001) johnson, j., Organizer, Director and Facilitator, University of Toronto Varsity Orientation Initiative, Camp Kandalore, indoor climbing facility and Seneca College Outdoor Educational Centre, 700 athletes. Included report to the Faculty ($7000.00). Funded, University of Toronto. (2000) johnson, j., Hazed and Confused: Changing the Initiation Culture in Varsity Athletics. Video commissioned by the Canadian Intrauniversity Sport (CIS) organization and the Faculty of Physical Education and Health. Wrote, directed, edited and produced the educational video distributed to University Athletic Departments across Canada ($3500). Funded CIS. (2000) johnson j., & P. S. Miller, Report and implementation for the Faculty of Physical Education and Health Student-Athlete handbook, University of Toronto ($4000.00). Funded, University of Toronto. (1998) johnson, j., & P.S. Miller, Orientation and transition experiences among intercollegiate student-athletes. Faculty of Physical Education and Health, University of Toronto ($8000.00). Funded, University of Toronto. RESEARCH PAPERS & PROFESSIONAL PRESENTATIONS *peer reviewed Henhawk, D., & j. johnson. (May 13-14, 2021). ~Owtsira Ohkara, Stories Across the Fire: Our Journeys Through Indigenous and Land-Based Education. Ecologies - University of Manitoba Eastern Transportation Corridor Collaborative Workshop. The University of Manitoba’s Architectural and Engineering Services and Office of Sustainability. Henhawk, D., & j. johnson. (May 30-June 1, 2021). Meskanaw Kamamawi Pimitisamak ~ the road that we walk together: Our journey of learning and leisure through Indigenous

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Land-Based Education in Manitoba. Virtual 2021 Congress of the Humanities and Social Sciences. Canadian Congress on Leisure Research. *Butryn, T., johnson, j., & M. Masucci. (November 5, 2020-postponed). Into the weeds: Exploring marijuana and CBD use in sports. North American Society for the Sociology of Sport, (NASSS). johnson, j. (April, 21, 2020). Alternatives to hazing. Online interactive seminar for Rugby Ontario. Toronto, Ontario. *Butryn, T., johnson, j., & M. Masucci. (July 7-9, 2020-postponed). An ethnographic content analysis of marijuana and CBD use in women athletes.7th International Conference on Qualitative Research in Sport and Exercise (QRSE). Durham, England, UK. *johnson, j. & B. Langlais. (January 23, 2020). Mino-bimaadiziwin Through Mentorship: The Photovoice Project. The 7th Annual Ongomiizwin-Research Indigenous Health Research Symposium. University of Manitoba, Bannatyne Campus. Winnipeg, Manitoba, Canada. *Butryn, T., johnson, j. & M. Masucci. (November 6-9, 2019). An ethnographic content analysis of marijuana and cannabidiol use among professional athletes. North American Society for the Sociology of Sport, (NASSS). Virginia Beach, Virginia, USA. *Deol, S., & j. johnson. (May 7-10, 2019). An intersectionality approach of immigrant girls' lived experiences with physical activity. International Physical Literacy Conference (IPLC). Winnipeg, Manitoba, Canada. johnson, j. (May 8, 2019). Sport film and society. Panel Member. Faculty of Kinesiology and Recreation Management Research Day. University of Manitoba, Winnipeg, Canada. *Chin, J., M. Masucci & johnson, j. (October 31-November 3, 2018). Bikes and beats: Engaging the San José Bike Party through mobile video ethnography. North American Society for the Sociology of Sport, (NASSS). Vancouver, British Columbia, Canada. *Butryn, T., Masucci, M., & johnson, j. (October 31-November 4, 2018). A "Notorious" spectacle: Reading Conor McGregor through a narrative lens. North American Society for the Sociology of Sport, (NASSS). Vancouver, British Columbia, Canada. *Chin, J., johnson, j., & M. Masucci. (June 6-8, 2018). Through the optical lens: Musings on developing a moving methodology. 6th International Conference on Qualitative Research in Sport and Exercise (QRSE). Vancouver, British Columbia, Canada.

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*johnson, j. (June 8-10, 2018). A vehicle for reconciliation: Paddling towards a re-imagined identity. CFP: The Politics of the Canoe: Activism and Resistance. Winnipeg, Manitoba, Canada. *johnson, j., & A, Ali. (November 1-4, 2017). In conversation with “nature”: Placing a decolonizing lens on land-based education for transformative possibilities. North American Society for the Sociology of Sport, (NASSS). Windsor, Ontario, Canada. johnson, j. (September 19-20, 2017). Transforming the Canadian sport culture: A national study of gender, race, sexuality, and violence in sport hazing as barriers to sport participation. Sport Canada Research Initiative Conference. Toronto, Ontario, Canada. johnson, j. (May 10, 2017). Hazing in sport: Two steps forward, one step back: Changing? The culture of sport hazing in the 21st century. Invited speaker for the Research Day showcase for the Health, Leisure and Human Performance Research Institute at the University of Manitoba. Winnipeg, Manitoba. *johnson, j., & A, Ali. (November 5-8, 2016). Glamping: The imperial tenting of the outdoors and the colonization of the wilderness. North American Society for the Sociology of Sport, (NASSS). Tampa Bay, Florida, USA. M. Norman & johnson, j. (November 1, 2016). Looking back before moving forward: An oral history of the physical cultures of Sandy Bay First Nation. (URGP-Funded). In conjunction with community members from Sandy Bay, including Elders, high school youth and professionals, we were able to complete the entire radio documentary of Elders memories and stories of physical culture and experiences in the community-45 minutes running. The final phase was playing the documentary for the community over Sandy Bay Radio in the early fall of 2016 followed by a call in show with selected Elders, youth and University professors. *johnson, j. (October 12, 2016). Two steps forward, one step back?: A preliminary analysis of a 3-year mixed methods study of varsity hazing knowledges’ and practices. Western Society for Kinesiology & Wellness annual conference, socio-cultural perspectives on physical activity, health, and sport. Reno, Nevada, USA. *Kim, J., & j. johnson. (2016, June). Mini U brochure: Advertising racial exclusion at the University of Manitoba, Canada? 2016 AIESEP International Conference: Blazing New Trails: Future Directions for Sport Pedagogy and Physical Activity. Wyoming, USA. *Kim J., & j. johnson. (2016, June). Managing acculturative stress through culturally responsive leisure for immigrants in Canada. 2016 AIESEP International Conference: Blazing New Trails: Future Directions for Sport Pedagogy and Physical Activity. Wyoming, USA. johnson, j., A., Richardson, J. Wilcott-Sie, J. Botelho, & C. Scheller. (February, 17, 2016). Okwiinowag Ojiimaan: The impact of traditional outdoor educational experiences. 20th Annual Recreation Connections Manitoba Conference. Winnipeg, Manitoba.

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*Masucci, M & j. johnson. (November 19-22, 2015). Building community through bicycling: An examination of “Neo-Activist” media strategies in the proliferation of the San José bike party. National Communications Association (NCA) 101st Annual Convention. Las Vegas, Nevada, USA. Ali, A., & j. johnson. (November 4-7, 2015). Skating on thin ice? A critical interrogation of Canada’s melting pastime. North American Society for the Sociology of Sport, (NASSS). Santa Fe, New Mexico, USA. *Kim, J., & j. johnson. (2015, November). Mini u brochure as their way to reproduce racial exclusion and whiteness at the University of Manitoba? The 8th Annual Strangers in New Homelands Conference. Winnipeg, Canada. *Kim, J., & j. johnson. (2015, November). The Power of leisure in managing acculturation stress for immigrants in Canada. The 8th Annual Strangers in New Homelands Conference. Winnipeg. johnson, j., M. Holman, J. Chin, E. J. Allan & M. Madden. (October 29, 2015). Transforming the Canadian sport culture: A National study of gender, race, sexuality and violence in sport hazing as barriers to sport participation. SSHRC Poster Presentation: Sport Canada Research Initiative Conference (SCRI). Kanata, Ontario, Canada. *Kim, J., & j. johnson. (2015, October). A critical ethnography of physical culture for Korean immigrants in Canada from the everyday perspective. Immigration, Ethnicity and Diversity in 150 Years of Canada Looking Back, Going Forward. Ottawa, Canada. *Kim, J., & j. johnson. (2015, October). Does mini u brochure reproduce racial exclusion at the University of Manitoba, Canada? Immigration, Ethnicity and Diversity in 150 Years of Canada Looking Back, Going Forward. Ottawa, Canada. *Kim, J., & j. johnson. (July 30, 2015). The Mini U brochure: Advertising racial exclusion at the University of Manitoba, Canada? Sixth International Conference on Sport and Society "Sport in the Americas”. University of Toronto, Toronto, Canada. johnson, j., M. Holman, J. Chin, E. J. Allan, M. Madden, K. Nelson, M. Signer & A. Krahn. (May 13, 2015). The landscape of varsity hazing in Canada: Preliminary results from a 3-year SSHRC funded study of the culture of hazing in Canadian interuniversity sport. Health, Leisure & Human Performance Research Institute Research Day 2015. University of Manitoba. *johnson, j., M. Masucci & J. Chin. (November 9, 2014). The moving social: Exploring the “politics” of the Bike Party movement. North American Society for the Sociology of Sport, (NASSS). Portland, Oregon, USA. *johnson, j., M. Masucci & J. Chin. (November 7th, 2014). Conference Session Organizer. Biciculture. North American Society for the Sociology of Sport, (NASSS). Portland, Oregon, USA.

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*johnson, j., & A. Ali. (November 9, 2014). The Green-Sport synergy. Bridging the gap between environmental and sport sociology. North American Society for the Sociology of Sport, (NASSS). Portland, Oregon, USA. *johnson, j., & J. Chin. (June 12-15, 2014). On the Fringe: Strategizing play to defray conflict within the matrix of team membership, community, and sport hazing. Asian Conference on the Social Sciences (ACSS). Osaka, Japan. *Ali, A., & j. johnson. (June 18-20, 2014). Skating on thin ice: The impact of climate change on backyard hockey in Southern Ontario. The Hockey Conference, University of Western Ontario. London, Ontario. johnson, j., M. Holman, J. Chin, E. J. Allan, M. Madden, K. Nelson & M. Signer. (May 14, 2014). Examining the Canadian Interuniversity Sport culture: A national study of gender, race, sexuality and violence in sport hazing. Health, Leisure & Human Performance Research Institute Research Day 2014. University of Manitoba. johnson, j., M. Holman, J. Chin, E. J. Allan & M. Madden. (October 29, 2013). Transforming the Canadian sport culture: A National study of gender, race, sexuality and violence in sport hazing as barriers to sport participation. SSHRC Poster Presentation: Sport Canada Research Initiative Conference (SCRI). Kanata, Ontario, Canada. *johnson, j., T. Butryn & M. Masucci. (October 24, 2013). A qualitative examination of knowledge of doping and anti-doping education among elite US and Canadian female triathletes. Council of University Professors and Researchers (CUPR), Physical and Health Education National Conference. Winnipeg, Canada. *johnson, j., & J. Chin. (August 19, 2013). Greenwashed?: A critical historical perspective of environmental initiatives in sport and physical activity. International Society for the History of Physical Education and Sport (ISHPES). TaiPei, Taiwan. *johnson, j., F. Moola, J. Lay, S. Pagatpatan & G. Faulkner. (June 23, 2013). “Oh, the places you'll go!:” A PhotoVoice exploration of Hamilton youths’ perceptions of their neighborhoods. Canada International Conference on Education (CICE). Toronto, Ontario, Canada. *Masucci, M., & j. johnson. (November 8, 2012). After mass: An exploration of the San José Bike Party and neo-activist bicycle movements in North America. North American Society for the Sociology of Sport (NASSS). New Orleans, Louisiana. *Chin, J. W. & j. johnson. (June 2, 2012). Complicating the impact of Title IX: A media analysis of hazing in female sports. The North American Society for Sport History (NASSH). Berkeley, California. *johnson, j., Chin, J. & Fitzgerald, A. (2012 March 28-April 1). “Catching” the green wave: A critical examination of the eco-marketing initiatives of professional sports

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teams. Cultural Studies Association Meeting—Environment, Space, and Place Division. San Diego, CA. *Masucci, M., & j. johnson. (February 24th-28th, 2012). You’ve got to fight for your right to party!: A qualitative exploration of the San José Bike Party. Paper presented at 2012 Association of American Geographers (AAG) Annual Meeting. New York, New York. *Masucci, M., T. Butryn & j. johnson. (November 4th, 2011). An examination of doping knowledge among world-class professional female triathletes. NASSS, North American Society for the Sociology of Sport, (NASSS). Minneapolis, Minnesota. *Chin, J. W. & j. johnson. (January 22, 2011). Making the team: Threats to health and wellness within sport hazing cultures. Health, Wellness and Society International Conference. Berkeley, California. *johnson, j., M. Masucci, & T. Butryn. (November 6th, 2010). A qualitative examination of doping knowledge among elite female triathletes. North American Society for the Sociology of Sport, (NASSS). San Diego, California. *Masucci, M. & j. johnson. (November 6th, 2010). “You’ve got to fight for your right to party!”: A qualitative exploration of the San José Bike Party. North American Society for the Sociology of Sport, (NASSS). San Diego, California. *johnson, j. (November 7th, 2009). Conference Session Organizer. Sport, “physical activity and the environment”. North American Society for the Sociology of Sport, (NASSS). Ottawa, Canada. *johnson, j. & L. Eliopulos. (November 7th, 2008). Shifting ice floes: The impact of climatic change on our physical experiences. North American Society for the Sociology of Sport, (NASSS). Pittsburg, Pennsylvania. *johnson, j. (November 1st, 2007). From the sidelines: The (in)vasion of space and the role of the coach in effecting team unity and identity construction. North American Society for the Sociology of Sport, (NASSS). Pittsburg, Pennsylvania. johnson, j. (May 4th, 2007). Boys, men and sport: Competing for the ideal body? The National Eating Disorder Information Centre: Body Image and Self Esteem: Shades of Grey. Toronto, Ontario. johnson, j. (March 22nd, 2007). On the sidelines: Team cohesion and the need to reintegrate the coach into the team building process. University of Windsor Research Day-Poster. johnson, j. & T. Vaillancourt. (March 22nd, 2007). Parents: The unacknowledged victims of childhood bullying. University of Windsor Research Day-Poster.

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*johnson, j. (November 2nd, 2006). Waiting in the liminal: The homophobic/homoerotic paradox of sport rites of passage. North American Society for the Sociology of Sport, (NASSS). Vancouver, Canada. *johnson, j. & M. Holman. (June 3, 2006). Lessons lived, lessons learned – Managing team hazing from the mistakes of others. North American Society for Sport Management Conference (NASSM). Kansas City, Missouri. *johnson, j. (May 22, 2006). Glory days: What form will the phoenix assume out of the ashes of sport hazing traditions? Proposed changes for historically humiliating and abusive initiation ceremonies. The North American Society for Sport History (NASSH). Glenwood Springs, Colorado. *johnson, j. (December 2, 2005). Surviving murderball: The body and the (re) construction of masculine identity through quad rugby. 3rd World Congress of Sociology of Sport, "Sport and Social Inclusion/Exclusion". Buenos Aires, Argentina. johnson, j. (April 26, 2004). At play with the enemy: Building stronger communities through outdoor adventure. Lamarsh Centre Graduate Symposium. York University, Toronto, Canada. *johnson, j. (October 31, 2003). Out in the wilderness: Cops and kids forging a new community? North American Society for the Sociology of Sport, (NASSS). Montreal, Canada. *johnson, j. (November 1, 2001). Tri-ing too hard: A case analysis of professional Canadian triathletes. North American Society for the Sociology of Sport, (NASSS). San Antonio, Texas. johnson, j. (March 2, 2001). Diverse perspectives in education from the OISE community. University of Toronto, Toronto. Canada. *johnson, j. (November 4, 2000). 1) Alternative initiations: Will a rope save us from the quagmire of hazing? 2) An Educational video on athletic initiations and hazing. North American Society for the Sociology of Sport, (NASSS). Colorado Springs, Colorado. *johnson, j. (May 23, 2000). The globalization of the initiation ceremony; Our boys overseas. Learneds Conference. University of Alberta, Canada. johnson, j. (April 11, 2000). Alternative programs: Sport initiations. LaMarsh Centre for Research on Violence and Conflict Resolution. York University, Toronto, Canada. *johnson, j. (November, 1999). Hazed and confused: Resolving the problems of hazing in sport. North American Society for the Sociology of Sport, (NASSS). Cleveland, Ohio.

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MEDIA, CONSULTANT, GUEST SPEAKER (December 18, 2020). Winnipeg Free Press. A stain on our game. Jeff Hamilton. https://www.winnipegfreepress.com/special/graham-james/ (December 8, 2020). TSN news. Affidavits outline alleged abuse, harassment and hazing in junior hockey. Rick Westhead. https://www.tsn.ca/affidavits-outline-alleged-abuse-harassment-and-hazing-in-junior-hockey-1.1561527 (January, 27, 2020). CBC news-The National. Laurence Vincent-Lapointe exonerated from doping charges-contaminated from boyfriend bodily fluids. Hosts, Adrienne Arsenault and Andrew Chang. (April, 5, 2019). Keynote Speaker with Dr. Holman. Transforming the culture of sport hazing. Ontario Coaches Conference. Coaches Association of Ontario, Markham, Ontario, Canada. (December 20, 2018). 1310 News Talk 1010 Toronto, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, John Moore. (December 17, 2018). CBC Radio, Hazing in the Military in Canada. Producer, Samantha Simon. (November 29, 2018). CBC News (online), 'It's toxic': Former NHLer Carcillo says he won't be silent about hockey's hazing culture. Writer, Jamie Strashin. (November 29, 2018). 1310 Global News Radio 640 Toronto, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, John Oakley. (November 29, 2018). 1310 News Radio Ottawa Today, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Mark Sutcliffe. (November 28, 2018). CTV News Winnipeg, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Kaitlyn Van De Woestyne. (November 28, 2018). CBC News, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Suhana Marchand. (November 28, 2018). 570 News, Kitchener Today with Brian Bourke, Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Brian Bourke. (November 27, 2018). The Arlene Bynon Show for SiriusXM. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Arlene Bynon.

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(November 25, 2018). CBC Radio 1-Cross Country Checkup. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Duncan McCue. (November 25, 2018). CBC news-online. When it comes to hazing, female athletes are just as vulnerable. Author, Duncan McCue. (November 22, 2018). CBC Thunder Bay. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Hayden Watters. (November 21, 2018). Radio NL in Kamloops BC. Host, Howie Reimer. (November 21, 2018). The Ryan Jespersen Show, on 630 CHED radio in Edmonton. Host, Ryan Jespersen. (November 20, 2018). CTV Winnipeg. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Beth MacDonnell. (November 20, 2018). 610CKTB in St. Catharine’s, Ontario. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Larry Fedoruk. (November 20, 2018). CBC News, the National. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Adrienne Arsenault, Ioanna Roumeliotis. (November 19, 2018). CTV Edmonton. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Katie Chamberlain. (November 19, 2018). CTV News Channel (national). Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Melissa Meyers. (November 19, 2018). CTV Edmonton. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Katie Chamberlain. (November 19, 2018). CBC National NEWS. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Andrew Nichols. (November 19, 2018). AM 640. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Producer, Alex Pierson. (November 16, 2018). CTV National NEWS. Alleged Sexualized Hazing incident at St. Michael’s College in Toronto. Host, Jill Macyshon. (November 15, 2018). Newstalk 1010 Toronto. Hazing at St. Michael’s College in Toronto. Host, John Moore. (March 21, 2017). Maclean’s Magazine. How to break the vicious cycle of hazing Can universities crack down on disgusting initiation rituals if students don’t want to stop?

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Meagan Campbell. http://www.macleans.ca/news/how-to-break-the-vicious-cycle-of-hazing/ (March 15, 2017). The Globe and Mail. Why is hazing still happening? They do it because they can. Newspaper article. (March 28, 2016). Facilitator for an anti-hazing education seminar and workshop for the University of Windsor Lancers coaches and athletes, supported by Lancer Athletic Department. (November 1, 2016). CBC radio, Sudbury. Interviewed regarding allegations of a hazing incident involving members of the men's basketball team at Laurentian University in Sudbury. (October 25, 2016). Invited guest speaker, Culturally Relevant Community Capacity Building Eastman Interlake Recreation Practitioners Conference, Gimli, Manitoba. (March 28, 2016). Office of Public Affairs and Communication, Daily News, Kevin Johnson. Coaches and athletes primed to tackle hazing. http://www.uwindsor.ca/dailynews/2016-03-24/coaches-and-athletes-primed-tackle-hazing (March 23, 2016). CTV News Windsor, nightly news. Anti-hazing seminar at the University of Windsor. (March 23, 2016). CBC evening news Windsor, host, Robin Brown, Producer. Anti-hazing seminar at the University of Windsor. (March 23, 2016). Facilitator for an anti-hazing education seminar and workshop for the University of Windsor Lancers coaches and athletes, supported by the Women’s campus safety grant-University of Windsor. (March 22, 2016). Invited featured guest on hazing in athletics, sport hazing workshop. CBC Radio 1, Windsor Morning with Tony Doucette (Peter Duck), Windsor, Ontario, Canada. http://www.cbc.ca/windsormorning/episodes/2016/03/22/sports-hazing-workshop/ Holman, M., & j. johnson. (March 18, 2016). Keynote Speakers. Understanding hazing culture: Taking the next step. Spring Soph Orientation (800 student leaders). University of Western Ontario, London, ON. (January 14-15, 2016). Invited consultant, presenter and facilitator for Queens University Athletics & Recreation Department, responsible for two days of workshops/consultation for student clubs/groups, teams, coaches, athletic department and students-at-large. Kingston, Canada.

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(October 8-11, 2015). Invited panelist on sports and sexual violence for the American Studies Association (ASA) annual conference. The (Re)production of Misery and Ways of Resistance. Toronto, Ontario, Canada. (March 27, 2015). Invited speaker/workshop facilitator, Bishops University, varsity and recreational athletes, as well as our Orientation Week volunteers, issues of hazing and initiations. (October 29, 2014). University of Manitoba, News Today-Featured Community Stories. http://news.umanitoba.ca/hazing-in-sport-informing-policy-across-north-america/ (October, 2014). Featured Researcher-UM Today, Community Stories, the University of Manitoba, Hazing in sport: Informing policy across North America. http://news.umanitoba.ca/hazing-in-sport-informing-policy-across-north-america/ (October 11, 2014). Guest Speaker on-The Classroom ESPN 1220 –Sayreville High School Football Sexual Hazing Case. Talk show hosted by Dr. Keith Strudler on FoxNewsRadio, (segment 2) on americanedtv.com. (April 9-10, 2014). Invited speaker and facilitator, Risk and Resilience, Institute for Child and Youth Studies (I-CYS), University of Lethbridge, Alberta. (March 19, 2014). Jackie Oncescu, Moss Norman, jay johnson, Shane Ray, Introduction to PhotoVoice. Recreation connections Manitoba annual provincial conference, Winnipeg, Manitoba. (January 21, 2014). Invited speaker and panelist, Knowing and Writing for your Audience - writing towards publication. Graduate Student Professional Development Series-Writing Workshop. The Faculty of Kinesiology and Recreation Management, University of Manitoba. (November 9, 2013). Guest Speaker on-The Classroom ESPN 1220 -the Hazing Culture in the NFL. Talk show hosted by Dr. Keith Strudler on FoxNewsRadio. (October 9, 2013). johnson, j. & Jackie Oncescu. Giving a Voice to All: introduction to Photovoice Methodology. Therapeutic Recreation Professional Development Day, Manitoba Therapeutic Recreation Professional Association. Recreation Connection. (September 24, 2013). High School Hazing in Lanigan Saskatchewan. Guest speaker on the Sheila Coles Show, CBC Regina, Saskatchewan. (September 24, 2013). High School Hazing in Lanigan Saskatchewan. Guest speaker, CBC Morning, Saskatoon, Saskatchewan. (July 25, 2013). Walk! Cycle! Wheel! Summer is a good time to get kids into active

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transportation. F. Moola, j. johnson, S. Prowse. Winnipeg FreePress, Arts & Life, Active Living Section. (November 21, 2012). What Can We Learn From Lance? Featured Panelist public forum on the ethics of doping in sports. Centre for Professional and Applied Ethics, University of Manitoba. (March 2, 2012). Hazed and Confused Workshop. Invited speaker and facilitator for all day workshop, University of Alberta, Faculty of Student Affairs, Athletics and Student Services. (December 23, 2011). Hazing Beyond the Frat House. Inside Higher Ed. Interview. http://www.insidehighered.com/news/2011/12/23/florida-am-death-illuminates-prevalence-non-greek-hazing (October 28, 2011). On-Air guest speaker, Hazing on the Neepawa junior Hockey Team. The Richard Brown Show News Talk 650 CKOM Saskatoon/News Talk 980 CJME Regina, www.ckom.com. (July 23, 2011). Invited Panelist, PBS production of Equal Time shown on KQED in California. The episode titled Sportsmanship examined the role of violence amongst spectators in light of the recent near death beating of a San Francisco Giants baseball fan. (August 7, 2008). Guest Speaker, invited guest speaker to the Missouri State High school activities association in Springfield to present a talk titled Preventing Hazing and Harassment in Sport Cultures to 500 student leaders, athletic Directors and coaches from across the State. (November, 2006). Print, University Affairs Magazine, Putting a check on hazing: Sports leaders look for a better option. (November 4, 2005). On-Air guest speaker, Liz Janzen Sports Radio Show KX 96/94.9 The Rock, Hazing in hockey. (Fall, 2005). Academic-Policy Liaison, Office of the Associate Vice Principal, Communications McGill University. (October 20, 2005). On-Air guest speaker, Drew Remenda Sports Show, 650 CKOM/980 CJME, Saskatoon, Sk., Hazing in hockey. (October 20, 2005). On-Camera guest, CBC Newsworld morning program Host Andrew Nichols, Hazing on McGill football team. (October 19, 2005). On-Air guest speaker, CBC Questionnaire, Winnipeg Mb. Katie Andrews, one-hour call in show, Hazing and sport.

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(October 19, 2005). Print, CBC News online, In-depth Bullying, Hazing: Passing on The Rites, Peter Hadzipetros. (October, 18, 2005). Print, Epoch Times Weekly, Hazing rituals and the sporting world. (October 1, 2005). On -Air guest speaker, CKNW/Corus Radio network Peter Warren National radio program, 2-5pm, Hazing in sports. (September 25, 2005). Print, Montreal Gazette, Bill Marsden: Hazing: A cruel ritual where everyone loses. (September 22, 2005). On-Air guest speaker, CBC Radio Broadcast: Ottawa, Hazing at McGill. (December 1, 2003). On-Air panelist. CBC-Canada Now and Newsworld, Hazing in Our Schools, Feature Topic. (September 22, 2003). Consultant. CNN-The Anderson Cooper Show, Hazing in American Colleges. (February 11, 2002). Invited panelist. Game On, CHRY 105.5 FM Toronto, Discussion panel on violence in sport surrounding their entry rituals. (October 18, 2001). Invited panelist and speaker. Michael Smith Seminars on Violence and Sport All Day Roundtable: Good Play: Reducing Violence in Sport. No Pain, Some Gain. How Ropes and Challenge Courses Can Change Hazing Practices in Athletics. (May 23-24, 2001). Facilitator. Moderator for the World Youth Day Summit, Sponsored by OPHEA, the Ontario Physical Health Education Association. (April 23, 2001). Guest Speaker. LaMarsh Centre for Research on Violence and Conflict Resolution, York University, Toronto, Canada. The Michael Smith Seminars on Violence and Sport: Picking up the Pieces: New Directions for Sport Initiations. (April 14, 2001). On-Air guest speaker. CKNW Radio, World News, Violence in Sport, Vancouver, British Colombia. (December 4, 2000). Invited speaker. LaMarsh Centre for Research on Violence and Conflict Resolution; Violence, Sexual and Physical Abuse in a Sporting Context. (November 20, 2000). Presenter. Break out session. Anti-bullying symposium presented by Cayre, in the York region, Recreation and Coaching, and panelist discussant bullying prevention strategies with a community focus. (October 13, 1999). Consultant and On-Air Panelist, CBC Newsworld, Sports Journal with Tom Harrington. Initiations in Varsity Athletics.

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TEACHING EXPERIENCE Associate Professor-Faculty of Kinesiology and Recreation Management, University of Manitoba, Winnipeg, Manitoba, 2012-Present Courses KPER 3460- Sociology of Physical Activity and Leisure

PHED 3360-Culturally Relevant Physical Education and Health PHED 4710-Outdoor Education and Leadership REC 4720-Wilderness Adventures (co-instructed) PHED 3710-Active Health and Human Potential (co-instructed) PHED 2442-Health Education (co-instructed) REC 3090-Sustainable Nature-Based Tourism and Recreation

PHED 3750-Lifestyle Activities PHED 2720-Developmental Games and Activities KPER 7160-Qualitative Methods and Research Design, (Graduate Course)

KPER 7006-Social Aspects of Physical Activity, (Graduate Course) KPER 7000- Research in Kinesiology and Recreation Management (Graduate Course)

Assistant/Associate Professor-Department of Kinesiology, San José State University, San José, California, 2007-2012 Courses

KIN 185/H-Senior Seminar KIN 101-Sport in America

KIN 160-History of Sport & PE KIN 164-Socio-cultural Perspectives KIN 100-SJSU Climate Solutions Initiative

KIN 15A-Beginning Basketball KIN 38-Beginning Jogging

KIN 35B-Intermediate Weight Training KIN 35A-Beginning Weight Training KIN 2A-Beginning Swimming KIN 2B-Intermediate Swimming KIN 2C-Advanced Swimming KIN 263-International Sport and Physical Education, (Graduate Course)

KIN 261-Historical Interpretations of Sport, (Graduate Course) KIN 260-Philosophy of Sport and Embodiment, (Graduate Course)

Contract Faculty, Department of Kinesiology-Sport Management, University of Windsor, Windsor, ON, 2006-2007 Courses 95-350-The Sociology of Sport and Physical Activity, 95-454-Conflict and Cooperation,

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95-400-An Examination of Hazing in the Sporting Context: Emphasizing Alternative Orientations, 95-320-Philosophy and Ethics of Sport and Physical Activity

Contract Faculty, Department of Kinesiology-Sport Management, University of Windsor, Windsor, ON, 2004-2005 Courses

95-398-Practicum, Theory and Analysis of Exercise, 95-500-The Social Body, (Graduate Level Course) 95-400- An Examination of Hazing in the Sporting Context: Emphasizing Alternative Orientations, 95-308-Strategic Planning of Sporting Events, and Principles of Sport Management, 95-454-Conflict and Cooperation

Course Director, York University, School of Kinesiology and Health Sciences, Toronto, ON, 2003-2004

Women in Sport in the 20th Century, Foundations of Kinesiology

Course Director, University of Toronto, Faculty of Physical Education and Health 2002-2003

Games of the World, Historical and Cross-Cultural Perspective Long term Occasional Teacher, Wellington County Board of Education, Guelph, ON 1994-1995

French Immersion, grades 8, 10, 11 GRADUATE STUDENT ADVISING-Thesis Advisor University of Manitoba 2013-present PHD level Brett Cumberbatch Black Masculinity-January 2021 Masters level Bryden Bukich (co-advisor) Indigenous Experiences with the Health Care

System (Start Fall, 2021) Cristine Vlcek Sex Education in University: An Exploratory

Qualitative Inquiry-(Proposal, 2020)

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Bree Langlais Mino-bimaadiziwin/Mino-pimatisiwin Through Mentorship: An Indigenous Interpretive Analysis of Living in a Good Way-Defended (August, 2020) SSHRC Canada Graduate Scholarship

Maria Rocha From Policy to Practice in Early Childhood

Education and Care Centers in Manitoba: ECE Perspectives –Defended (December, 2020)

Mahdi Ebrahimian (co-advisor) The Use of Performance Enhancing Substances

Amongst Recreational Gym Users, Knowledge, Prevalence and Risk Factors-Defended (March, 2020)

Bianca Matwyczuk (co-advisor) 2017 Canada Sumer Games Legacy:

Understanding the use of Canada Games Sport for Life Centre Post-Event-Fall, 2017 (part time)

Simrit Deol New Immigrant Girls’ Experiences with Physical

Activity: An Intersectionality Approach- Defended (August, 2018)

Guanpeng Zhou (co-advisor) A qualitative examination of the experiences of

Winnipeg Urban Aboriginal Youth Rec and Read Program-Defended (August, 2018)

Committee Member Jeremy Botelho Neither Cold Nor Hot, I Spit You Out: Towards a

Half-Breed Existentialism. Defended (January 2021)

Kaitlyn Kuryk PHD in (Sociology). Health Care Systems and

Policy, Social Construction of Medical Knowledge, and Sociology of Care. Comprehensive exams completed.

Jason Mergler PHD. Fringe Sport Athlete Development, Athlete

Progression, Training Histories, and Developmental Pathways.

Julie Brodeur Passion Among Hockey Parents and Focus on the

Determinants and Outcomes of both Harmonious and Obsessive Varieties of Passion.

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Tiffany Addison The Impact of Fan Empathy Toward Football Players Suffering from Concussions on Fans’ Openness to Rule Changes Designed to Reduce the Prevalence of Concussions in Professional Football.

Courtney Gabrielle Exploring How Business Improvement Areas (BIA)

Conduct Events and Engage with Customers using Social Media-Proposed

Marian Juliet Brainoo (Sociology)-Mhealth Technologies and Doctor-

Patient Relationships in the Context of Consumer Cultures-Proposed

Brittany Streuber Self-Compassion and Self-Regulation of Physical

Activity: Reactions to Failure, Fear of Self-Compassion and Gender Differences-Defended

Avril Dongwan He The Impact of Recent Policy Revisions Addressing

Doping and Gender Rules in Sport on Women Student-Athletes in China Defended

Kendra Nelson Family feud? Exploring sibling relationships in

competitive youth sport-Defended Alix Krahn Motivation, Mental Toughness, or Manipulation?

Exploring verbal and mental abuse within the context of elite female volleyball in Manitoba-Defended

San José State University 2007-2012 Thesis Advisor Laura Andersson Sudden Cardiac Death in Running: The

Psychosocial Impact on Running Communities-Defended (College Outstanding Thesis Award)

Lindsey Eliopulos “Firing the Pigskin Real Right”: Media

Representations of Jessica Simpson & Tony Romo-Defended

Ryan Laperle Monitoring ankle rehabilitation with Wii fit-

Defended

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Dr. jay johnson

2021

Jim Rubalcava The Forgotten Man: A Historical Account of Mark Brown’s Involvement With the First Gay Games-Defended

Brittany Syrovatka Hazing in High School Athletics: A Qualitative

Examination of Private and Public Academic Institutions-Defended

Kirky Kirkendall Into the Wild: A Qualitative Exploration of Outdoor

Experiential Adventure on First Year Female University Students –Defended

Josh Pendleton Program Directors’ Perceptions of Quality in

NATA-Accredited Post Professional Athletic Training Education Programs-Defended

Paul Ramirez Barriers to Physical Activity for Latino Youth-

Defended Lisa Herbert The Relationship Between Marathon Race Size and

Medical Infrastructure-Defended Tony Gianotti Academic Achievement, Delinquent Behavior, and

Sport:The ability of organized school-based sports programs to positively impact educational opportunity, motivation, and ability for low-achieving students through positive youth development-Defended

Committee Member Michael Dao An Examination of Sport for Development and

Peace Program Implementation Using an American Hegemonic Framework-Defended

Daniel Yusim Athletic Trainer’ Perspectives Of Violence And

Injury In Professional Ice Hockey-Defended Erick Schlimmer The Utility of Athlete-Tailored Mental Health

Services of NCAA Division 1-A Universities: Psychology Professionals Perspectives-Defended

Alexis Waddel-Smith Motivational Factors Of Elite Female Triathletes:

Examining The Longevity Of Sport-Defended

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Sarah Merkel The Effect of Stretching and Tool-Assisted Friction Massage on Hamstring Flexibility in College Athletes-Defended

FACULTY/DEPARTMENT, UNIVERSITY, ACADEMY, COMMUNITY SERVICE Faculty/Departmental Faculty representative for University of Manitoba Faculty Association (UMFA). (2020-present). Member, Equity, Diversity and Inclusion Committee (EDI). (2019-present). Member, Indigenous Engagement Circle’s Academic Work Group (IEC-AWG). (2020-present) Member, Tenure and promotion committee (voted on by faculty). (2019-2020). Member, Faculty committee to examine online courses and education in FKRM (2019-present). Member, Indigenous Land-Based Education Conference, assisting in the planning for the University of Manitoba Faculty of Kinesiology and Recreation Management (FKRM) who hosted a two-day land-based education conference with 26 Indigenous educators and 4 Elders from across Manitoba (August, 28-29, 2019). Member, hiring committee for Position 27063: Instructor I/ II in Physical and Health Education. (Winter, 2019). Member, Indigenous Engagement Circle (IEC), formerly Indigenous Achievement/Community Engagement Working Group, Faculty of Kinesiology and Recreation Management. (Winter 2017-present). Member, Indigenous Knowledge Circle assisting in the planning for the University of Manitoba Faculty of Kinesiology and Recreation Management (FKRM) who hosted a three-day Sport and Reconciliation Gathering in (February, 2018). Faculty Advisor, Faculty of Kinesiology and Recreation Management, PHE student led physical education and health conference, (February, 2019). Member, of the hiring committee for two positions (two Community Engagement Coordinators) and the Project Manager. The project is the Indigenous Sport and Wellness Strategy (June, 2018). Member, hiring committee for: Position Number 24875: Assistant/Associate Professor in Exercise/Health Psychology. (Winter, 2018).

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2021

Member, hiring committee for: Position Number 24876: Assistant/Associate Professor in Physical and Health Education. (Winter, 2018). Member, (2012-present). Graduate program volunteer, chair 3-4 graduate student thesis proposals/defences each year. Member, Graduate Admissions and Awards Committee, Faculty of Kinesiology and Recreation Management. (Fall 2016-2018). Hosted youth from Verna Kirkness Program. We engaged in Indigenous ceremony with an Elder, PhotoVoice qualitative methodology on campus and outdoor adventure across campus. (Spring 2016-2018). Committee Founding Member and Committee Representative of the Equity, Diversity and Inclusion Committee, Faculty of Kinesiology and Recreation Management, University of Manitoba. (Fall 2015). Chair and Founding Member, University of Manitoba, FKRM Mentorship Committee. This group is tasked with designing a two-pronged Faculty Mentoring and Mentorship Program to assist new faculty in their transition and adjustment to their new environment in academe by providing both an informal and formal internal program for the development of community, leadership and academic excellence. (Fall 2015-Spring 2016). Member, Faculty/Staff Awards Committee, member for the Faculty of Kinesiology and Recreation Management, University of Manitoba. (2012-2016). Member, Undergraduate Awards Committee, the Faculty of Kinesiology and Recreation Management, University of Manitoba. (2014-2018). Committee Member and Committee Representative of Tenure and Promotion (TAP) Committee, University of Manitoba. (Fall 2013-2014). Elected Member, Steering Committee for Developing a Strategic Research Plan for the Faculty of Kinesiology and Recreation Management, the University Manitoba. (2013-2015). Member, Faculty representative, FKRM Local Area Safety and Health Committee (LASHC). (2013-2015). Workplace Health and Safety Representative for the Faculty of Kinesiology and Recreation Management, University of Manitoba. (2013-2015). 2nd Floor Alternate Fire Warden Max Bell Centre, University of Manitoba. (2014).

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2021

Member, San José State University, Center for Applied Research on Human Services (CARHS) grants academy. (2012). Elected Interim Departmental Activity Coordinator, Faculty of Kinesiology, SJSU. (2010). Committee Member of General Education, Department of Kinesiology, SJSU. (2011-2012). Committee Member of Undergraduate Committee, Department of Kinesiology, SJSU. (2007-2011). Committee Member of Activity Committee, Department of Kinesiology, SJSU. (2008-2009). Faculty Member Representative, Climate Solutions Course San José State University. (2008). Member of Faculty Liaison Committee, Faculty of Human Kinetics, University of Windsor. (2006-2007). Member of Scholarship Selection Committee, Faculty of Human Kinetics, University of Windsor. (2004-2005). Member of Gender Equity Committee, Faculty of Human Kinetics, University of Windsor. (2004-2005). University Member, Faculty representative for University of Manitoba Faculty Association (UMFA). (2020-present). Member, Office of Sustainability Committee to Indigenize space at University of Manitoba. Indigenous and non-Indigenous faculty and staff who meet at the University of Manitoba to strategize and promote Indigenous initiatives on campus and in the community. (Winter 2019-present). Member, Eastern Transportation Corridor Design Charrette Steering Committee. (2020-present). Member, Gaa wii ji'i diyaang. Indigenous and non-Indigenous faculty and staff who meet at the University of Manitoba to strategize and promote Indigenous initiatives on campus and in the community. (2018-present). CATL, land-based education certification, (April, 2019).

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2021

Member, University of Manitoba SSHRC evaluation sub group, responsible for evaluating applications for Doctoral Fellowships, Vanier CGS, and SSHRC CGSM. (Fall 2016-2018). Member, Mobility and Accessibility Research Group. A cross, multi and interdisciplinary research group centred in Winnipeg Manitoba, composed of University of Winnipeg and Manitoba Faculty, and community members whose working mandate is collaboratively address local issues related to mobility, motility, accessibility, transportation and migration. 2015-2018. Committee Member of the University of Manitoba Visionary (re)Generation’ Planning Working Group whose terms of reference are to provide technical expertise to the planning process and its final products of the Fort Gary campus plan including the area master plan (Southwood/Smartpark), and phase one site plan (Southwood). (Fall 2013-2016). Member, Qualitative Research Group (QRG), The University of Manitoba. (Fall 2013-present). Member, Critical Environments Research Group (CERG), a University of Manitoba research group sponsored by the Faculty Development Initiative and from the Riddell Faculty of Environment, Earth and Resources. (2014-present). Academic Senator, Representative for the Faculty of Kinesiology and Recreation Management, University of Manitoba. (2013). Department Representative, Circle of Inclusion, Gender Equity Committee, University of Manitoba. (Fall 2012). Academic Senator, San José State University. (2011-2012). University Committee Member of the San José State University Library Committee. (2011-2012). University Committee Member of the San José State University Library Sub-Committee, Open Access. (2011-2012). University Member of the San José State University Sustainability Committee. (2011-2012). University Committee Member-San José State University Sports Club Disciplinary Adjudication Committee. (2011-2012). Academy

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2021

Member, Editorial Board of The History, Culture and Sociology of Sports (specialty section of Frontiers in Sports and Active Living). (2020-present). Committee Member, the North American Society for the Sociology of Sport (NASSS) elections committee. (2014-present). Research Associate, Health, Leisure & Human Performance Research Institute, University of Manitoba. (2012-2019). Elected Member-at-Large, North American Society for the Sociology of Sport (NASSS) Executive Board Member. (2010-2012). Committee Chair, North American Society for the Sociology of Sport (NASSS) Barbara Brown Student Paper Competition. (2010-2012). Committee Member, North American Society for the Sociology of Sport (NASSS) Sustainability Committee. (2010-2012). INVITED MANUSCRIPT REVIEW/GRANT REVIEWER-*Refereed Journals (2020/2021). Invited reviewer-Research Manitoba. Master’s funding proposals, adjudication team. (2020/2021). Invited reviewer-Social Sciences and Humanities Research Council (SSHRC) Insight Grant proposal, adjudication team. (2015-present). Invited reviewer-World Anti-Doping Agency (WADA), competitive, blind peer reviewed grants in the social sciences. (2014-16). Invited reviewer-Social Sciences and Humanities Research Council (SSHRC) Insight Grant proposal, adjudication team. Member, Editorial Board of The History, Culture and Sociology of Sports (specialty section of Frontiers in Sports and Active Living). (2020-present). *Refereed Journals *Sociology of Sport Journal (SSJ) *International Journal of Sport Science (IJSS) *International Review Sport Sociology (IRSS) *Qualitative Research in Sport, Exercise and Health (QRSEH) * International Journal of Environmental Research and Public Health *Sport Management Review (SMR) *Sport in Society, Cultures, Commerce, Media, Politics (SIS) *Journal of Sport and Exercise Psychology (JSEP) *Event Management Review (EMR)

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*Psychology of Sport and Exercise Education (PSEE) *Leisure Sciences (LS) *International Journal of Environmental Research and Public Health (IJERPH) *European Journal for Sport and Society Community Volunteer, Sir William Osler School. Committee to create land based education and sustainable playground space on the school grounds. (2018-present). Volunteer-the Knowles Centre- a community-based, nonprofit social service agency for children, adolescents and young adults facing difficult times in their lives. (2012-2020). Faculty Advisor/Coach-Swim Club San José State University. (2010-2012). Faculty Advisor/Coach-Triathlon Club San José State University. (2007-2012). Faculty Advisor-SJSU Wrestling Club San José State University. (2007-2008). Founder/Organizer Evelyn Memorial Scholarship Fund. Endowed Kinesiology Scholarship Triathlon Fundraiser, University of Windsor. (2005). Coach, Phoenix place, womens' second stage facility. Trained 10 women for their first triathlon, fundraiser. (2003-2004). Researcher, Toronto Daily Food Bank. Conducted interviews. Collected, collated and prepared data for publication on usage. (2002). Organizer, University of Toronto Community Triathlon, University of Toronto. (2001). President and co-organizer, coach, University of Toronto Triathlon Club. (1999-2002). PROFESSIONAL ASSOCIATION MEMBERSHIPS -Qualitative Research in Sport and Exercise (QRSE) Sport Canada Research Initiative Conference (SCRI) -North American Society for the Sociology of Sport (NASSS) - International Society for the History of Physical Education and Sport (ISHPES) -North American Society for Sport Management (NASSM) -North American Society for Sport History (NASSH) -Associate researcher-LaMarsh Centre for Research on Violence and Conflict Resolution -Ontario Physical Health Education Association (OPHEA) -Ontario Association of Triathletes (OAT)

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Dr. jay johnson

2021

-Triathlon Canada- National Team Member 2000-2002, 2011 -National Coaching Certification Program (NCCP) -Ontario Teacher’s Federation (OTF) -Triathlon Canada -OASES, Certified Fitness Consultant -Coaching Association of Canada (CAC) ADDITIONAL QUALIFICATIONS -Ontario Teacher’s Certificate, Intermediate/Senior, Phys Ed. and Health, Individual and Society -Special Education part 1, University of Western Ontario -C.P.R. Heartsaver Plus -Red Cross First Aid, Emergency Level -O.T.A.S. (Ontario Teachers Aquatic Standard) -NCCP Intro to Competition -NCCP Coaching Level 1 Triathlon, Triathlon, theory, practical, technical -Volleyball, theory and practical -NCCP Coaching Level 2, Basketball, theory and practical -NCCP Coaching Level 2, Wrestling, theory, practical, technical - Fun with Athletics, (alternatives) for athletics in the classroom -American Red Cross-Lifeguard, CPR-First Aid -OASES CFC -Assistant Alpine Tower Instructor -Low Ropes facilitator -Certified Fitness Consultant -High Ropes facilitation-Low ropes/cooperative games facilitation

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THIS IS EXHIBIT “C” REFERRED TO IN THE AFFIDAVIT OF JAY JOHNSON SWORN BEFORE ME BY VIDEO-

CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TO THECOVID-19 PANDEMIC FROM THE CITY OF WINNIPEG, IN PROVINCE OF

MANITOBA, TO THE CITY OF TORONTO, IN THE PROVINCE OFONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

SUE TAN

097

Court File No.: CV-20-642705-00CP

ONTARIO SUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR

HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD., KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS

HOCKEY CLUB INC., 2325224 ONTARIO INC. o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY

BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY ACADEMY LTD., OTTAWA 67'S LIMITED PARTNERSHIP c.o.b. OTTAWA

67's HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY

WOLVES HOCKEY CLUB LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as

BRANDON WHEAT KINGS, BRANDON WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY

SPORTS AND ENTERTAINMENT CORPORATION, EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB,

INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS

& ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER

JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA

ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT TIGERS, SWIFT CURRENT TIER 1

FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS & ENTERTAINMENT INC. o/a

WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC. WARRIORS o/a

MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB,

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649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE

TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE

BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES OLYMPIQUES DE GATINEAU INC.,

HALIFAX MOOSEHEADS HOCKEY CLUB INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA

INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-

NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS, LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN

MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a CATARACTES SHAWNIGAN, CLUB DE HOCKEY

JUNIOR MAJEUR VAL D’OR INC. o/a VAL D'OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY LE PHOENIX, 9264-8849 QUÉBEC

INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS HOCKEY c.o.b. FLINT

FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY

AMERICANS HOCKEY LLC, and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

ACKNOWLEDGMENT OF EXPERT'S DUTY

1. My name is Jay Johnson. I live in the City of Winnipeg, in the Province of

Manitoba.

2. I have been retained by lawyers for the Plaintiff, Koskie Minsky LLP to provide

my unbiased expert opinion in support of the certification motion in this matter.

3. I acknowledge that it is my duty to provide evidence in relation to this proceeding

as follows:

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(a) To provide opinion evidence that is fair, objective and non-partisan;

(b) To provide opinion evidence that is related only to matters that are within

my area of expertise;

(c) To provide such additional assistance as the court may reasonably require,

to determine a matter in issue.

4. I acknowledge that the duty referred to above prevails over any obligation which I

may owe to any party by whom or on whose behalf I am engaged.

November 29, 2021 _____________

______________ JAY JOHNSON

100

Carcillo et al. Plaintiffs and

Canadian Hockey League et al. Defendants Court File No.: CV-20-642705-00CP

ONTARIO SUPERIOR COURT OF JUSTICE

Proceeding commenced at TORONTO

ACKNOWLEDGMENT OF EXPERT'S DUTY

KOSKIE MINSKY LLP 900-20 Queen Street West Toronto ON M5H 3R3

James Sayce LSO#: 587630M jsayce@kmlaw.ca Tel: 416-542-6298 Nathalie Gondek LSO#: 77660H ngondek@kmlaw.ca Tel: 416-542-6286 Sue Tan LSO#: 74826A stan@kmlaw.ca Tel: 416-595-2117 Lawyers for the Plaintiffs

101

Carcillo et al. Plaintiffs and

Canadian Hockey League et al. Defendants Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

Proceeding commenced at TORONTO

AFFIDAVIT OF JAY JOHNSON (SWORN NOVEMBER 29, 2021)

KOSKIE MINSKY LLP900-20 Queen Street West Toronto ON M5H 3R3

James Sayce LSO#: 587630M jsayce@kmlaw.ca Tel: 416-542-6298

Nathalie Gondek LSO#: 77660H ngondek@kmlaw.ca Tel: 416-542-6286

Sue Tan LSO#: 74826A stan@kmlaw.ca Tel: 416-595-2117

Lawyers for the Plaintiffs

102

Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

B E T W E E N :

DANIEL CARCILLO and GARRETT TAYLOR Plaintiffs

- and -

ONTARIO MAJOR JUNIOR HOCKEY LEAGUE, CANADIAN HOCKEY LEAGUE, WESTERN HOCKEY LEAGUE, QUEBEC MAJOR JUNIOR

HOCKEY LEAGUE, BARRIE COLTS JUNIOR HOCKEY LTD., GUELPH STORM LTD., HAMILTON BULLDOGS FOUNDATION INC., KINGSTON FRONTENACS HOCKEY LTD., KITCHENER RANGERS JR. A. HOCKEY CLUB, LONDON KNIGHTS HOCKEY INC., MISSISSAUGA STEELHEADS

HOCKEY CLUB INC., 2325224 ONTARIO INC. o/a MISSISSAUGA STEELHEADS, NIAGARA ICEDOGS HOCKEY CLUB INC., NORTHBAY

BATTALION HOCKEY CLUB LTD., OSHAWA GENERALS HOCKEY ACADEMY LTD., OTTAWA 67'S LIMITED PARTNERSHIP c.o.b. OTTAWA

67's HOCKEY CLUB, THE OWEN SOUND ATTACK INC., PETERBOROUGH PETES LIMITED, 649643 ONTARIO INC. o/a 211 SSHC CANADA ULC o/a SARNIA STING HOCKEY CLUB, SOO GREYHOUNDS INC., SUDBURY

WOLVES HOCKEY CLUB LTD., WINDSOR SPITFIRES INC., MCCRIMMON HOLDINGS, LTD., 32155 MANITOBA LTD., A PARTNERSHIP c.o.b. as

BRANDON WHEAT KINGS, BRANDON WHEAT KINGS LIMITED PARTNERSHIP, CALGARY FLAMES LIMITED PARTNERSHIP, CALGARY

SPORTS AND ENTERTAINMENT CORPORATION, EDMONTON MAJOR JUNIOR HOCKEY CORPORATION, KAMLOOPS BLAZERS HOCKEY CLUB,

INC. KAMLOOPS BLAZERS HOLDINGS LTD., KELOWNA ROCKETS HOCKEY ENTERPRISES LTD., PRINCE ALBERT RAIDERS HOCKEY CLUB INC., EDGEPRO SPORTS & ENTERTAINMENT LTD., QUEEN CITY SPORTS

& ENTERTAINMENT GROUP LTD., BRAKEN HOLDINGS LTD., REBELS SPORTS LTD., SASKATOON BLADES HOCKEY CLUB LTD., VANCOUVER

JUNIOR HOCKEY LIMITED PARTNERSHIP and VANCOUVER JUNIOR HOCKEY PARTNERSHIP, LTD c.o.b. VANCOUVER GIANTS, WEST COAST HOCKEY LLP, WEST COAST HOCKEY ENTERPRISES LTD., o/a VICTORIA

ROYALS, MEDICINE HAT TIGERS HOCKEY CLUB LTD., 1091956 ALTA LTD. o/a THE MEDICINE HAT TIGERS, SWIFT CURRENT TIER 1

FRANCHISE INC. and SWIFT CURRENT BRONCOS HOCKEY CLUB INC. o/a THE SWIFT CURRENT, ICE SPORTS & ENTERTAINMENT INC. o/a

WINNIPEG ICE, MOOSE JAW TIER 1 HOCKEY INC. D.B.A. MOOSE JAW and MOOSE JAW WARRIORS TIER 1 HOCKEY, INC. WARRIORS o/a

MOOSE JAW WARRIORS, LETHBRIDGE HURRICANES HOCKEY CLUB,

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649643 ONTARIO INC. c.o.b. as SARNIA STING, KITCHENER RANGER JR A HOCKEY CLUB and KITCHENER RANGERS JR “A” HOCKEY CLUB, LE

TITAN ACADIE BATHURST (2013) INC., CLUB DE HOCKEY JUNIOR MAJEUR DE BAIE-COMEAU INC. o/a DRAKKAR BAIE-COMEAU, CLUB DE HOCKEY DRUMMOND INC. o/a VOLTIGEURS DRUMMONDVILLE, CAPE

BRETON MAJOR JUNIOR HOCKEY CLUB LIMITED o/a SCREAMING EAGLES CAPE BRETON, LES OLYMPIQUES DE GATINEAU INC.,

HALIFAX MOOSEHEADS HOCKEY CLUB INC., CLUB HOCKEY LES REMPARTS DE QUÉBEC INC., LE CLUB DE HOCKEY JUNIOR ARMADA

INC., MONCTON WILDCATS HOCKEY CLUB LIMITED, LE CLUB DE HOCKEY L’OCÉANIC DE RIMOUSKI INC., LES HUSKIES DE ROUYN-

NORANDA INC., 8515182 CANADA INC. c.o.b. as CHARLOTTETOWN ISLANDERS, LES TIGRES DE VICTORIAVILLE (1991) INC., SAINT JOHN

MAJOR JUNIOR HOCKEY CLUB LIMITED, CLUB DE HOCKEY SHAWINIGAN INC. o/a CATARACTES SHAWNIGAN, CLUB DE HOCKEY

JUNIOR MAJEUR VAL D’OR INC. o/a VAL D'OR FOREURS, 7759983 CANADA INC. c.o.b. as CLUB DE HOCKEY LE PHOENIX, 9264-8849 QUÉBEC

INC. c.o.b. as GROUPE SAGS 7-96 AND LES SAGUENÉENS, JAW HOCKEY ENTERPRISES LP c.o.b. ERIE OTTERS, IMS HOCKEY c.o.b. FLINT

FIREBIRDS, SAGINAW HOCKEY CLUB, L.L.C., EHT, INC., JOHN DOE CORP. A o/a EVERETT SILVERTIPS HOCKEY CLUB, WINTERHAWKS

JUNIOR HOCKEY LLC, PORTLAND WINTER HAWKS INC., THUNDERBIRDS HOCKEY ENTERPRISES, L.L.C., JOHN DOE CORP. B o/a SEATTLE THUNDERBIRDS, BRETT SPORTS & ENTERTAINMENT, INC., HAT TRICK, INC., JOHN DOE CORP. C o/a SPOKANE CHIEFS, TRI-CITY

AMERICANS HOCKEY LLC, and TOP SHELF ENTERTAINMENT, INC. and JOHN DOE CORP. D o/a TRI-CITY AMERICANS

Defendants

Proceeding under the Class Proceedings Act, 1992

AFFIDAVIT OF CATHERINE MACDONALD (Sworn November 29, 2021)

I, Catherine MacDonald, of the Regional Municipality of Clarington, in the

Province of Ontario MAKE OATH AND SAY:

1. I am a legal assistant with the law firm Koskie Minsky LLP, counsel for the

plaintiffs in this action, and as such I have knowledge of the matters to which I hereinafter

depose. I have also been provided with information by James Sayce, the lawyer at Koskie

Minsky LLP with primary carriage of this file, which I believe to be true.

2. I swear this affidavit in support of the Plaintiff's motion for certification.

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3. Attached as Exhibit "A" are excerpts from the book titled, "Playing with Fire" by

Theo Fleury.

4. Attached as Exhibit "B" are excerpts from the book titled, "I Am Nobody" by

Greg Gilhooly.

5. Attached as Exhibit "C" are excerpts from the book titled, "Why I Didn’t Say

Anything" by Sheldon Kennedy.

6. Attached as Exhibit "D" are excerpts from the book titled, "Crossing the Line"

by Laura Robinson.

7. Attached as Exhibit "E" is a copy of the article titled, "RCMP office in jail-sex

case 'dysfunctional,' court hears" dated September 18, 2014.

8. Attached as Exhibit "F" is a copy of the report following a public interest

investigation into an incident occurring in the Kamloops, British Columbia cell, File No.

PC-2010-3263.

9. Attached as Exhibit "G" is a copy of the article titled, "Top Mountie on defensive

after cell sex accusations".

SWORN by Catherine MacDonald, via video-

link from the Municipality of Clarington, in

the Province of Ontario, before me in the City

of Toronto, in the Province of Ontario, on

November 29, 2021, in accordance with O.

Reg. 431/20, Administering Oath or

Declaration Remotely.

Catherine MacDonald

A Commissioner for taking Affidavits (or as may be)

Nathalie Gondek LSO#: 77660H

105

THIS IS EXHIBIT “A” REFERRED TO IN THE AFFIDAVIT OF CATHERINE MACDONALD SWORN BEFORE ME BY

VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

NATHALIE GONDEK

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THIS IS EXHIBIT “B” REFERRED TO IN THE AFFIDAVIT OF CATHERINE MACDONALD SWORN BEFORE ME BY

VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

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VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

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VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

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THIS IS EXHIBIT “E” REFERRED TO IN THE AFFIDAVIT OF CATHERINE MACDONALD SWORN BEFORE ME BY

VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

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THIS IS EXHIBIT “F” REFERRED TO IN THE AFFIDAVIT OF CATHERINE MACDONALD SWORN BEFORE ME BY

VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

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THIS IS EXHIBIT “G” REFERRED TO IN THE AFFIDAVIT OF CATHERINE MACDONALD SWORN BEFORE ME BY

VIDEO-CONFERENCE IN ACCORDANCE WITH O. REG 431/20 DUE TOTHE COVID-19 PANDEMIC FROM THE MUNICIPALITY OF

CLARINGTON, IN PROVINCE OF ONTARIO, TO THE CITY OF TORONTO,IN THE PROVINCE OF ONTARIO, THIS 29TH DAY OF NOVEMBER, 2021.

A COMMISSIONER FOR TAKING AFFIDAVITS, ETC.

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Daniel Carcillo et al. Plaintiffs and

Canada Hockey League et al. Defendants Court File No.: CV-20-642705-00CP

ONTARIOSUPERIOR COURT OF JUSTICE

Proceeding Commenced in TORONTO

REPLY MOTION RECORD (CERTIFICATION)

KOSKIE MINSKY LLP900-20 Queen Street West Toronto, ON M5H 3R3

James Sayce LSO#: 58730M jsayce@kmlaw.ca Tel: 416-542-6298

Nathalie Gondek LSO#: 77660Hngondek@kmlaw.ca Tel: 416-542-6286

Sue Tan LSO#: 74826A stan@kmlaw.ca Tel: 416-595-2117

Lawyers for the Plaintiffs