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)

EXHIBIT Q

Claims of Peyton Manning H.G.H. Use Raise Nagging Questions - The New York Times

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http://nyti.ms/22u4VcQ

PRO FOOTBALL

Claims of Peyton Manning H.G.H. Use
Raise Nagging Questions
Sports of The Times
By MICHAEL POWELL DEC. 27, 2015

Let’s back up this garbage truck. In 2011, we had a 36-year-old quarterback who
could not grip a football properly. His triceps had withered, and his right arm had
turned into a frail reed. He needed spinal fusion surgery, the insertion of a titanium
plate in his neck, and that came on the heels of earlier neck operations.
Peyton Manning was trying desperately to get back into shape in hopes of
returning to football, even though his neck and spine were in a state of disrepair.
And the N.F.L., the players’ union and all of us fans were all right with that.
The shock is not that this fading star is reported in an investigative documentary
by Al Jazeera to have obtained human growth hormone. He denies this, vehemently,
angrily, and we’ll get to his protestations.
Rather the shock would be to discover that more than a few men in this morally
compromised sport are completely clean. In the last two decades, the weight of
N.F.L. linemen has jumped by 50, 60, 70 pounds, and men the size of linebackers
play wide receiver. At the draft combine, teams weigh in players like so many steers
and then chart their every improbable sprint, vertical jump and bench press.

http://www.nytimes.com/2015/12/28/sports/football/claims-of-peyton-manning-doping-raise-nag... 12/30/2015

Claims of Peyton Manning H.G.H. Use Raise Nagging Questions - The New York Times

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Players are bigger, faster, heavier, which leads to more brain-dissolving
concussions, heart attacks, and ligaments and joints stretched to the breaking point.
Would you blame any of these battered men — a majority of whom can have their
contracts ripped up after the first torn ligament — for popping a pill, slipping a
syringe under the skin or lying back after a game and smoking a fat one? As a dope
trafficker claimed in Al Jazeera’s documentary, one football player began using and
saw his contract jump to $2 million per year, from $400,000.
“Football and doping kind of go hand in hand: big strong men who crush each
other and recover from injury faster,” noted Roger A. Pielke Jr., a professor at the
University of Colorado Boulder who studies sports drug testing and governance.
More broadly, Al Jazeera’s documentary underlines the globalization of sports
doping. Fly to the Bahamas to meet ethically compromised doctors, then take a
cross-country flight to meet a chemistry-loving naturopath and drive around Austin,
Tex., with a pharmacist boasting of the players inflated through better doping.
As Renee Anne Shirley, former head of the Jamaican Anti-Doping Commission
noted, the Bahamas connection opens a door to the Caribbean, which has seen many
sprinters, hurdlers and jumpers implicated in drug-testing scandals.
In baseball, we assume progress. The biceps of home run hitters no longer bear
resemblance to those of Captain America. This said, a former Major League Baseball
investigator told Al Jazeera that one in five players is taking something.
M.L.B. responded that it cashiered this investigator. That claim might erode his
credibility, or speak to his righteousness.
Drug taking in baseball varies wildly. Mets relief pitcher Jenrry Mejia was twice
disqualified this season for using the steroid stanozolol, which in today’s high-tech
doping world is the equivalent of driving a Khrushchev-era tank. The odds of getting
blown up veer toward near certainty. The Mets nonetheless gave a new contract to
Mejia, who must sit out 162 games, perhaps giving him time to update his regimen.
Let’s circle back to Manning. He looked at the ESPN cameras Sunday and
denied all, emphatically, roundly.

http://www.nytimes.com/2015/12/28/sports/football/claims-of-peyton-manning-doping-raise-nag... 12/30/2015

Claims of Peyton Manning H.G.H. Use Raise Nagging Questions - The New York Times

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“I think I rotated between being angry, furious,” he said. “Disgusted is really
how I feel, sickened by it.
“What hurts me the most about this, whoever this guy is, this slapstick trying to
insinuate that in 2011, when more than less I had a broken neck — I had four neck
surgeries.” He added, “It stings me, whoever this guy is, to insinuate that I cut
corners.”
Manning is likable and does earnest well. He is a great quarterback, an all-time
great, and who wouldn’t want to believe him?
Nagging questions pop up like too-early flower stems. Pielke argues we need to
revisit H.G.H., a protein that activates receptors that tells cells to turn on growth.
Perhaps it could speed healing. A medical center is preparing long-term studies.
For now, however, legal use is tightly circumscribed.
On Sunday, Charles Sly, the man described by Al Jazeera as a doctor of
pharmacy, claimed everything he said in the undercover films was a boast and a lie.
In Al Jazeera’s documentary he can be heard saying that Manning attended an
anti-aging clinic in Indianapolis, known as the Guyer Institute of Molecular
Medicine. Sly said Manning obtained H.G.H., which was prescribed and mailed to
Manning in his wife’s name.
Manning said he went to Dr. Dale Guyer’s center only to use the hyperbaric
chamber. Dr. Guyer released a denial of Sly’s claims, saying that Sly was not even
working as an intern at the clinic at the time.
“I have no reason to believe these allegations are based in fact or have any
truth,” the doctor said.
If Sly fabricated his 2011 service at the center, however, how did he know that
Manning and his wife had been patients there?
Further, it’s not clear if Manning’s wife received H.G.H. Based on the required
conditions, she would not appear to qualify.

http://www.nytimes.com/2015/12/28/sports/football/claims-of-peyton-manning-doping-raise-nag... 12/30/2015

Claims of Peyton Manning H.G.H. Use Raise Nagging Questions - The New York Times

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Caveats should be piled in a heap here. Al Jazeera’s documentary breaks
intriguing and suggestive ground and establishes that the doping world is umbilically
attached, doctor to doctor. There is, however, no undercover video of Manning or
Guyer.
And Sly and the other characters appear to be slippery sorts, sweaty salesmen in
search of another mark.
Then again, Victor Conte of Balco and Anthony Bosch of Biogenesis did not
resemble high elders in the American Medical Association. But they ran
sophisticated operations, and their customers, who rarely tested positive, included
some of the greatest athletes in the world.
That fact alone argues that football’s elders would be wise to spare us ritual
denials and outrage for now. Let’s open this box a little wider.
Email: [e-mail]
A version of this article appears in print on December 28, 2015, on page D1 of the New York edition with
the headline: Doping Claims Raise Nagging Questions .

© 2015 The New York Times Company

http://www.nytimes.com/2015/12/28/sports/football/claims-of-peyton-manning-doping-raise-nag... 12/30/2015