Case: 1:15-cv-10989 Document #: 69 Filed: 01/22/20 Page 1 of 3 PageID #:980

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
PAUL MONTADOR, Executor and Estate
Trustee of the Estate of STEVEN R.
MONTADOR, Deceased,

Civil Action No.: 1:15-cv-10989
Honorable John Z. Lee

Plaintiff,
v.
NATIONAL HOCKEY LEAGUE and
NATIONAL HOCKEY LEAGUE BOARD
OF GOVERNORS,
Defendants.

DECLARATION OF GREGORY S. BAILEY IN SUPPORT OF
DEFENDANTS’ UNOPPOSED MOTION TO REASSIGN CASE
PURSUANT TO LOCAL RULE 40.4
I, Gregory S. Bailey, declare under penalty of perjury the following:
1.

I am one of the attorneys representing Defendants National Hockey League and

National Hockey League Board of Governors (together, the “NHL” or “Defendants”) in the
above-captioned action. I make this declaration in support of Defendants’ Unopposed Motion to
Reassign Case Pursuant to Local Rule 40.4.
2.

Attached hereto as Exhibit A is a true and correct copy of the United States

Judicial Panel on Multidistrict Litigation (“JPML”) Order creating the NHL Concussion MDL.
3.

Attached hereto as Exhibit B is a true and correct copy of the docket from the

District of Minnesota in the matter titled Daniel Carcillo and Nicholas Boynton v. National
Hockey League and National Hockey League Board of Governors (the “Carcillo Action”), Case
Number, 0:18-cv-01715-SRN-BRT.
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 Case: 1:15-cv-10989 Document #: 69 Filed: 01/22/20 Page 2 of 3 PageID #:980

4.

Attached hereto as Exhibit C is a true and correct copy of the Complaint filed in

the Carcillo Action.
5.

Attached hereto as Exhibit D is a true and correct copy of the Answer filed in the

Carcillo Action.
6.

Attached hereto as Exhibit E is a true and correct copy of the docket from the

Northern District of Illinois in the Carcillo Action, Case Number 1:19-cv-06156.
7.

Attached hereto as Exhibit F is a true and correct copy of McCrory et al.,

Consensus Statement On Concussion In Sport: The 4th International Conference On Concussion
In Sport Held In Zurich, November 2012.
8.

Attached hereto as Exhibit G is a true and correct copy of excerpts of McCrory et

al., Consensus Statement On Concussion In Sport The 5th International Conference On
Concussion In Sport Held In Berlin, October 2016.
Dated: January 22, 2020

Respectfully submitted,
/s/ Gregory S. Bailey
Gregory S. Bailey
SKADDEN, ARPS, SLATE,
MEAGHER & FLOM LLP
155 North Wacker Drive
Chicago, Illinois 60606
(312) 407-0700
gregory.bailey@skadden.com
Attorney for Defendant National Hockey League
and National Hockey League Board of Governors

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 Case: 1:15-cv-10989 Document #: 69 Filed: 01/22/20 Page 3 of 3 PageID #:980

CERTIFICATE OF SERVICE
I, Gregory S. Bailey, hereby certify that the foregoing Declaration of Gregory S. Bailey
in Support of Defendant Pfizer’s Inc.’s Reply in Support of Its Motion for Summary Judgment
and Defendant Pfizer Inc.’s Concise Response to Plaintiff’s Local Rule 56.1(b)(3)(C) Statement
of Additional Material Facts in Support of Its Opposition to Summary Judgment was served on
counsel of record through the CM/ECF system on March 1, 2019
s/Gregory S. Bailey
Gregory S. Bailey
Counsel for Pfizer Inc.