HOWARD v. AL JAZEERA AMERICA, LLC et al

Filing 1

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-4367752) filed by RYAN JAMES HOWARD. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Civil Cover Sheet, # 23 Summons AL JAZEERA AMERICA, LLC, # 24 Summons LIAM J. COLLINS, # 25 Summons DEBORAH DAVIES)(Herman, Andrew)

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Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring

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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

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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

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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

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and raises questions about.
Manning issued a statement Saturday night strongly denying the allegations,
claiming that "whoever said this is making stuff up."

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"Knowing Peyton Manning and everything he stands for, the Denver Broncos

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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.

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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

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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

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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.

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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.”

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“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.

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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.

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Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring

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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.

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Explosive Documentary Links Peyton Manning, Major Athletes To Doping Ring

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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
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CONVERSATIONS
583 Comments

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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?

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