ZIMMERMAN v. AL JAZEERA AMERICA, LLC et al

Filing 1

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-4367715) filed by Ryan C Zimmerman. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Civil Cover Sheet, # 23 Summons, # 24 Summons, # 25 Summons)(Lerner, Scott)

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EXHIBIT L Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Like Edition: US  FRONT PAGE Page 1 of 12 POLITICS ENTERTAINMENT WHAT'S WORKING HEALTHY LIVING WORLDPOST HIGHLINE HUFFPOST LIVE 5.6m Follow ALL SECTIONS Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring The quarterback and his wife received human growth hormone in 2011, an alleged supplier asserts in a new undercover investigation.  12/26/2015 09:01 pm ET | Updated 1 day ago Travis Waldron  Sports Reporter, The Huffington Post Ryan Grim Washington Bureau Chief, The Huffington Post   JOE AMON/GETTY IMAGES Denver Broncos quarterback Peyton Manning during a 2015 NFL game. A new report alleges that Manning and his wife obtained human growth hormone, which is banned in the NFL, when he was hurt in 2011. An Indianapolis anti-aging clinic supplied quarterback Peyton Manning with human growth hormone, a performance-enhancing drug banned by the NFL, a pharmacist who once worked at the clinic asserts in a new special report from Al Jazeera’s Investigative Unit. The report, “The Dark Side,” is the result of a monthslong investigation in which Liam Collins, a British hurdler, went undercover in an attempt to expose the http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 2 of 12 widespread nature of performance-enhancing drugs in global sports. As a cover story, Collins tells medical professionals tied to the trade of performance-enhancing drugs that he is hoping for one last shot at glory at the 2016 Olympics in Rio de Janeiro, Brazil. Manning is just one of many high-profile players the report names Learn more about mindfulness. and raises questions about. Manning issued a statement Saturday night strongly denying the allegations, claiming that "whoever said this is making stuff up." Focus on the present moment. Albert Breer @AlbertBreer LEARN HOW Follow Personal statement from Peyton Manning released by the Broncos ... 10:49 PM - 26 Dec 2015 780 405 The Denver Broncos also responded to the allegations against Manning, releasing Practice meditation and mindfulness. GET TIPS the following statement: Join our mindfulness conversation. "Knowing Peyton Manning and everything he stands for, the Denver Broncos Aetna @Aetna Follow support him 100 percent. These are false claims made to Al Jazeera, and we don't believe the report. Peyton is rightfully outraged by the allegations, which he emphatically denied to our organization and which have been publicly renounced by the source who initially provided them. Aetna Need a boost? Push through your afternoon with these tips for improving your energy level. https://t.co/zd6NHHPnmp https://t.co/z3bluj56bv 9 hours ago Reply Retweet Favorite   Visit aetnamindfulness.com Throughout his NFL career, particularly during his four seasons with the Broncos, Peyton has shown nothing but respect for the game. Our organization is confident Peyton does things the right way, and we do not find this story to be credible." The full report, which was shared in advance with The Huffington Post, is viewable FOLLOW HUFFPOST     here: HuffPost Like 5.6m http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Sports Page 3 of 12 Like 52k HUFFPOST NEWSLETTERS Get top stories and blog posts emailed to me each day. Newsletters may offer personalized content or advertisements. Learn More. address@email.com Subscribe! SUGGESTED FOR YOU • 1. Critics Pick The Worst Movies Of 2015 As part of the investigation, Collins connected with Charlie Sly, a pharmacist based in Austin, Texas, who worked at the Guyer Institute, the Indiana-based anti-aging clinic, in 2011. Manning missed the 2011 season, when he was a member of the Indianapolis Colts, after undergoing neck surgery. In the documentary, Sly tells Collins, who is taking secret video of his interactions, that he was “part of a medical team that helped [Manning] recover” from the surgery. Sly alleges that the clinic mailed growth a day ago live.huffingtonpost.com The Huffington Post HuffingtonPost.com (AOL) worst • 2. 50% Of Voters Would Be Embarrassed By Trump As President hormone and other drugs to Manning’s wife, Ashley Manning, so that the quarterback’s name was never attached to them. “All the time we would be sending Ashley Manning drugs,” Sly says in the video. “Like growth hormone, all the time, everywhere, Florida. And it would never be under Peyton’s name, it would always be under her name.” Manning and his wife also came to the clinic after its normal business hours for intravenous treatments, Sly tells Collins on the undercover video. Manning left the Colts after the 2011 season to sign with Denver. The NFL banned human growth hormone in 1991, but did not begin testing for it until 2014. No player has ever tested positive. “would never be under Peyton’s name, it would It always be under her name." Manning’s agent denied the details of the report to Al Jazeera, calling Sly’s assertions “outrageous and wrong.” But the statement does not deny that growth hormones were shipped to Manning's wife, only insisting that such matters were a matter of medical privacy. a week ago live.huffingtonpost.com HuffingtonPost.com (AOL) donald trump • 3. Musicians Holding Out From Joining Streaming Services Manning “has never done what this person is suggesting,” his agent told Al Jazeera. “The treatment he received at the Guyer Institute was provided on the advice of his physician and with the knowledge of team doctors and trainers.” http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 4 of 12 “Any medical treatment received by Ashley is a private matter of hers, her doctor, and her family,” the agent said. WATCH: Al Jazeera Reporter Details Investigation Behind 'The Dark Side' Doping Doc 1 Jeff Zelevansky via Getty Images The credibility of the report hinges largely on whether Sly should be believed, or whether he's simply concocting stories to impress Collins. Several details lend significant credibility to Sly's assertions. First, Sly and the ring he is associated with do, in fact, obtain drugs for Collins, which the network says it retained as evidence. In a stunning scene, Taylor Teagarden, an eight-year MLB veteran, appears in one of the undercover videos, openly discussing his use of performance-enhancing drugs during the previous season. Al Jazeera confirmed that Sly did work at the anti-aging clinic that treated Manning; it is difficult to imagine how Sly would have had knowledge of any arrangement to ship drugs to Manning's wife if he were not operating with genuine insider knowledge. (Sly also describes an interaction with Manning, telling Collins that the quarterback is “really cool if you just sit down with him.”) Collins, in some ways, was the perfect athlete to put at the center of the operation. He's no stranger to the shade, having himself been tied up in a fraud scam in recent years. Beyond the allegations against Manning, the report calls into question the effectiveness of testing regimes meant to prevent performance-enhancing drug use in professional sports, from American leagues to the Olympics. Collins’ undercover quest took him from the Bahamas, where he connected with a doctor that claimed to supply performance-enhancing drugs to Bahamian Olympic athletes, to Canada, where he met naturopathic physician Brandon Spletzer and pharmacist Chad Robertson, who devised a “cutting edge” drug program for Collins that included up to 10 injections each day. http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 5 of 12 Collins then connected with Sly, who has “taken smart drugs to a whole new level,” according to Spletzer. “The Dark Side” paints a picture of an underground marketplace where athletes can easily obtain drugs that are hard to detect even with sophisticated drug tests like those implemented by MLB, the NFL and the Olympics. And it raises questions about how serious the owners of professional sports teams are about rooting out drug use, which can make the games more exciting and profitable, while doing damage to the bodies of players, not owners. “ take a guy with average genetics and make I can him a world champion." “No one’s got caught, because the system’s so easy to beat,” Robertson, the pharmacist, brags to Collins. “And it still is, that’s the sad fact. I can take a guy with average genetics and make him a world champion.” Robertson designed a program for Collins that included prescription fertility and hormone drugs, other substances labeled as “not for human consumption” and illegal drugs. Sly, meanwhile, preached the effectiveness of Delta-2, a hormone supplement that is “steroidal in nature” but is not an anabolic steroid, according to online product descriptions. “There's a bunch of football players who take this, and a bunch of baseball players who take it too," Sly tells Collins in the documentary. “Delta-2 is not for use by anybody subject to performance-enhancing drug tests,” state online reviews for the product. Major League Baseball has banned the drug explicitly. The report does not link Manning to Delta-2, but Sly and Robertson name multiple football players as customers, including Green Bay Packers linebacker Mike Neal. Neal, Sly says, connected him with multiple teammates, including defensive end Julius Peppers. Pittsburgh Steelers linebacker James Harrison is another NFL player he has supplied, Sly says. Sly also names Philadelphia Phillies first baseman Ryan Howard and Washington Nationals infielder Ryan Zimmerman as players who received the drug from him. He also claims in the report he gave drugs to Mike Tyson. Delta-2 is designed to stay ahead of drug tests, Sly explains on video. He tells Collins that he provided the drug to Dustin Keller, a tight end who last played for the Miami Dolphins and allegedly used Delta-2 while in college at Purdue University and then before the NFL Combine, according to Sly. (Keller did not respond to Al Jazeera’s requests for comment). “We just used Delta-2 because it wasn’t detectable,” Sly says. http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 6 of 12 Sly also says that he provided Clay Matthews, Green Bay’s Pro Bowl linebacker, with the prescription painkiller Percocet to help him deal with pain before at least one game. He also brags in one undercover video that Matthews texted him in an attempt to obtain Toradol, a powerful painkiller that is banned in many countries but not in the United States. Harrison, Zimmerman and Howard all denied using the drugs to the network Neal, Peppers, Matthews and Tyson did not respond to Al Jazeera’s request for comment. Robertson, the pharmacist, and Spletzer, the neuropathic physician, did not respond to Al Jazeera’s request for comment. Sly, when pressed by Al Jazeera, backtracked, saying that his claims about supplying the drugs to athletes were “false and incorrect.” In a subsequent statement to Al Jazeera, he walked back the comments even further, saying that Collins took advantage of him while Sly was grieving the death of his fiancée. http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 7 of 12 CORRECTION: A previous version of this article said the NFL banned human growth hormone in 2011. The league actually banned it in 1991. The NFL and its players agreed to begin implementing an HGH testing system in 2011 and began testing in 2014. Also on HuffPost:  Amazing Photos From The 2015 NFL… MORE: Peyton Manning, Clay Matthews, Performance Enhancing Drugs, NFL, MLB, Ryan Howard, Al Jazeera, Must Reads FOLLOW SPORTS   GET THE NEWSLETTER Suggest a correction address@email.com Subscribe! YOU MAY LIKE Around The Web • 1. The Most Unfortunate Photos Ever Taken a year ago urbantabloid.com Urban Tabloid UrbanTabloid.com (sponsored) http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 8 of 12 Recommended For You • 1. Research reveals the 4 stages before a heart attack CONVERSATIONS 583 Comments Sort by Top Add a comment... Cara Bosse · Wicked Fairy at Black Forest, Germany And here come the moral relativists to the defense of the rich and powerful -let all the big sports boys use illegal drugs, but keep sending black kids to jail for years for possession of marijuana. Like · Reply · 365 · Dec 26, 2015 9:57pm · Edited David A. Ochs · Hawk missile you mean like that steroid cheat barry bonds? dave Like · Reply · 44 · Dec 26, 2015 10:13pm Jerry Johnson · Works at Tri Counties Bank Wow, it's only black kids. Amazing! Like · Reply · 74 · Dec 26, 2015 10:19pm Merkin Muffly Jerry Johnson Better check your white privilege broh, I'll throw down. Like · Reply · 83 · Dec 26, 2015 10:22pm Show 10 more replies in this thread Tom Street · Works at Retired He clearly is not on performance enhancing drugs this year. Like · Reply · 153 · Dec 26, 2015 9:20pm Luke Hancock · Community Prep School As a Bronco fan, I LOL'd. Like · Reply · 27 · Dec 26, 2015 9:49pm Peter Eggert Because they started testing in 2014. He started in 2011 after his surgery. Then all of a sudden he comes back and is the 2nd Broncos Jesus in a row in 2012/2013? Then he comes back down to mere mortal status these last two years? http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 9 of 12 http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 10 of 12 http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Page 11 of 12 http://www.huffingtonpost.com/entry/peyton-manning-human-growth-hormone_567f16e... 12/29/2015 Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring Advertise User Agreement Privacy Comment Policy About Us About Our Ads Contact Us Page 12 of 12 FAQ Copyright © 2015 TheHuffingtonPost.com, Inc. | "The Huffington Post" is a registered trademark of TheHuffingtonPost.com, Inc. 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