eric lindros - statement of claim

8/9/2019 Eric Lindros - Statement of Claim

1/15

Court

F

ile N

o.

CV

-14

-514188

ONT

ARIO

S

UPERIO

R

COU

RT

OF

JUS

TICE

ETW

EEN

(Cou

rt Sea

l)

ERIC

LINDRO

S

-

and -

PAU

L STEWA

RT,

HEHUF

FINGT

ONPOST

.COM, NC

,

A

OL I

NC.,and

AOL

CANA

DA I

NC.

A

MENDE

D

STATE

MENT OF

CLAIM

TO

TH

E DEFE

NDANT

S):

Plain

tiff

Defendants

A

LEGAL

P

ROCEED

ING

HAS

BE

EN C

OMMEN

CED

AGA

INST YOU

by

the

Plainti

ff. The

Claim

made against

yo

u

is

set

out

in t

he follow

ing

pages.

IF

YOU

WIS

H

T

O

DEFEN

D THIS

PRO

CEEDIN

G, ou

or

an

Ontario

la

wyer ac

ting

for you

must

prepar

e

a

Stateme

nt f Defen

ce

in

Form

8A

pre

scribed by

the Ru

les

of

ivil

Pro

cedure,

ser

ve

t

on

the

Plaintiff

s

lawyer

or

w

here

the

P

laintiffdoe

s

not have a

law

yer,

s

erve it

on the

Plaintiff

, and fi

le

it

with

proof

of

service

in

thi

s

co

urt

office,

WITH

IN

TWEN

TY

D

AYS

af

ter

this

St

atement

of Claim

is

served

an you,

i

you

are

se

rved

in

Ontario

f

you

are served

in

another

province or

territory

of

Canada

or

in

the

United

States

of

America,

the

period

for

serving and

fi l

ing your

State

ment

of Defe

nce

i

s forty

d

ays.

f

you

are serv

ed

outsid

e Canada

and

the Unit

ed

St

ates

ofAmer

ica,

he

peri

od

is

sixty

d

ays.

: tJir_~UL

~[i

TNIS._,

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~~~

f~~

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RSUAN f

l

U

MUDIFIL

CE

CQNFORM~

MENI A

~LE L

A

REGLE

26.02 ~ _

~

T

HE

ORDER

OF

L ORDON

NANCE

DU

~

`~

DATE

AI

—

EffIER

STICE

OUR

SUP~RIEURE

DE

JUSTICE


2/15


3/15

-3-

CL IM

1.

The

laintiff

claims

against each

of

the

defendants,

on

a oint

and several basis:

(a)

damages n

the amount of 150,000;

(b)

aggravated damages

n

the amount of

100,000;

(c) interim

interlocutory and permanent injunctions enjoining the

defendants

from

publishing

the defamatory statements

and

imputations

particularized

herein in any

form

or

by

any

medium;

(d)

interim

interlocutory and permanent injunctions enjoining the

defendants

from

making

or

continuing

any

publication

of

any

kind

whether

by

way

of

the Internet

or

otherwise,

which

states alleges

or

expresses the

opinion

that

the defamatory

statements

and imputations

particularized

herein

are

true

in

whole or in part;

(e)

interim

interlocutory

and permanent injunctions

enjoining the

defendants

from

publishing or causing

to be published

or otherwise disseminating

or

distributing

in

any manner whatsoever,

whether

by way of the

Internet or

otherwise,any

statements

or

communications

which

refer

to the

plaintiff

by

name,

by depiction or by description;

f ~ pre

-judgment and post-judgment

interest

in accordance

with the

Courts

of

Justice Act R.S.O. 1990,

. C.43, as amended;

(g) costs

of

this

action on

a

substantial

indemnity

basis

plus all

applicable

taxes; and


4/15

(h)

Such

further

and

other

relief

as

his Honourable

Court

may deem ust.

Parties to

the Claim

2.

The

plaintiff,

Eric

Lindros

Lindros )

is

an individual

residing

in

the City of Toronto,

in

the

Province of

Ontario.

Lindros spent

13 seasons playing

hockey

in

the

National

Hockey

League (the

NHL )

for

the New

York

Rangers,

Toronto

Maple

Leafs, Dallas

Stars, and

Philadelphia

Flyers.

3.

The

defendant, Paul

Stewart Stewart ) is

an individual residing

in

the

Town of

Wapole,

n the

State of

Massachusetts,

U.S.A.

Stewart

is

a former professional hockey

player

and

a former

referee.

Stewart carries

on

business as an

author and hockey

refereeing

consultant.

He

egularly

publishes columns on

topics relating to hockey on

the

Huffington

Post.

4.

The

Huffington

Post

is

an

online newspaper,

news aggregator and

blog publisher

that

is

comprised

of

national

(U.S.),

local

i.e., city-specific)

and international

(including

Canadian)

ditions

accessible via

the

Internet.

5.

The

Huffington

Post

is

published, owned and operated by the

defendants

The

HuffingtonPost.com, Inc, OL

Canada Inc., and OL

nc.

( the

OL

efendants ).

6.

The

HuffingtonPost.com,

Inc.

is

a

corporation under

the laws of Delaware.

7.

OL

Canada Inc.

is

a

corporation under

the

laws of the Province

of Ontario.

8.

OL

Inc. is

a

corporation under the laws of Delaware. OL

Inc. is the parent

company

of

the

defendants, The HuffingtonPost.com,

Inc.

and

OL Canada Inc.


5/15

-5

-

Writing

and Publication

of

the Article

9.

In

or

about

July

2014,

Stewart wrote an

article

entitled Hecklers,

Hooligans and

the

Striped-Shirted

Maitre D

the

Article ).

10.

On or

about

July

16,

2014,

the AOL

Defendants published

the Article on the

Huffington

Post,

accessible at

http.//www.huffingtonpost.com/paul-stewart/hecklers

-hooligans-and-th_b_5591462.html

the

Initial

Publication ).

Upon

the Initial

Publication,

the

Article

was

ccessible

freely to all

persons

n

the world with

access

o

the

Internet and

as part of

the

U.S,

Canadian

and other

editions

of the

Huffington Post.

The

Article was

n

fact

accessed and read

by a

large number of

people in Canada,

the United

States and

around

the

world,

particulars of which

are

in

the

exclusive knowledge of

the

AOL

Defendants.

11.

The Article

included

the following

words

of

and

concerning

the plaintiff:

Eric

Lindros was

a

player got off

with

on the wrong

foot and we

never

developed

a

rapport

because

neither

he

nor

wanted one.

t started out

innocently

enough.

was

working an

afternoon

Philadelphia

-New

Jersey

game at the

Spectrum;

the

back

end of

ahome-and-home.The

Devils

won

the

previous

game,

-4, n

a

game

efereed by

Mark

Faucette.

The

game got

chippy

late

in

the third

period,

with

about 4 penalty

minutes being handed out

in

the

final

five minutes,

ncluding

roughing

penalties to Lindros and Scott Stevens

in

the waning

seconds

of

the game.

The

start

of

the game t

the

Spectrum

was delayed several minutes. had

to wait for the red

light

on

the scorer's table to indicate that the broadcast

had

returned from

a commercial

and

it

was OK o

drop the opening

faceoff.

During

the delay,

made

mall

talk with several of

the

Devils

and

Flyers

on

the ice.

said

hello

to

Mark

Recchi

and

talked

to

Bernie

Nicholls.

then tried

to

greet

the 19

-year

-old rookie

Lindros.

Hey,

Eric.

How

are

things

going?

How's

your dad? asked.


6/15

The

response: [Bleep]

you.

Just

drop the

bleeping]

puck already.

Lindros was apparently in

a bad

mood because

he'd

recently missed

12

games

with

a knee

injury,

the team

was

in a losing skid, and

he'd

had a

tough

game n New

ersey. This

game was also

played

about a

week after

Lindros

had

to

go

to court

in

Toronto

after

the

Koo Koo

Bananas

incident.

You

know

what? Those

were his

problems,

not

mine. But

we were

about

o

have

a mutual

problem.

Right off

the

opening faceoff,

Lindros bulled forward and

drilled

Nicholls

under

the chin with

his stick.

ditched Lindros

on

ahigh-sticking

penalty.

Before the

game, had

brought a tube filled with posters to

Flyers'

equipment manager

Jim Turk Evers.

The posters,

which

depicted

Recchi

and

Lindros,

were

to

be autographed

and

then

donated to

a

charity auction.

had

done

a

similar

thing

in other

cities,

such

as

a am Neely and

Ray

Bourque

poster

in

Boston,

and

a

Mario

Lemieux

and

Jaromir

Jagr

in

Pittsburgh.

After

the

game,

want o Turk

to

collect

the

poster

tube.

Stewy,

you're not going

to like this, Evers said. I

don't

have

them.

What

do

you

mean

you

don't have them?

asked.

Well,

Rex

signed

the

posters

but when

Ericfound

out

they were

or you, he

tore

every

one

of

them

up. I'm sorry

about hat.

never

spoke to

Eric

Lindros again.

One

year,

much

later

in his career when

he

was

with

the

Rangers,

ended

up

getting him on

eight

minor

penalties that

season. caught

some

heat

or

t

from

John

Davidson

on

the

Rangers'

broadcasts,

but the

truth

of the

matter

was his:

did NOT

o out

of

my

way

o invent

penalties on Lindros

-- or any

player

--

but

wasn't going

to

give

that guy a

break

on anything

borderline

that

might

have let

slide with a

player who had

gained

acceptability

with

me.

With

some layers, on the

other

hand,

a bad

relationship

can

be

fixed

over

time.


7/15

Libellous

Conduct

by

the

Defendants

12.

The

words

written

by

Stewart n the Article

and published

by

the OL Defendants

are

inaccurate,

untrue, and

defamatory

of

the plaintiff in their

nature and

ordinary

meaning,

as ollows:

a)

The

statement

that Lindros did

not want

a

rapport with

Stewart

s

false and

makes

Lindros

out

to be

unfriendly

or

hostile;

b)

The

statement

that Lindros swore

i.e.

bleeped ) at

Stewart

is false and

makes

Lindros out

to

be unfriendly,

hostile,

rude

and insulting;

c)

The

statement

that

Lindros refused

to sign

posters intended

for

a

charity

auction,

and more

shockingly,

tore

them

up because

they were

solicited

by

Stewart, is false

and makes

Lindros out to be

unfriendly,

hostile,

rude,

insulting,

vindictive, cruel,

uncharitable

and generally

a despicable

person;

and

d)

The

statement

that

Lindros

failed

to

gain

acceptability

with

Stewart alsely

attributes blame or

that

alleged

failure

and further

falsely

makes

him out o

have

done something wrong or

improper such

as he false

allegations

in a)

to

(c),

above)

o justify

that

unacceptability

and

Stewart's

conduct towards

him

as a

referee.

These

statements

impute

moral

fault

to

or

personal

conduct

of the Plaintiff

that

a

reasonable

person

would consider

disreputable.

As

a result, reasonable

and

ordinary

readers

of the

Article

would regard

Lindros

with

contempt

or

ridicule.

13.

s a

consequence,

of

the Initial Publication,

the

Plaintiff

suffered

damages to this

reputation for

which

the

Defendants

are

responsible.


8/15

Republication

of

Libel;

Damages

14. The

Article

was

published by

Stewart

and

the

AOL

Defendants

with the knowledge

and

intention

that

it

would be

republished

and

redisseminated

via

linking

from

other

websites

on

the Internet,

via quotation or

paraphrasing

in

whole or

in

part

on other

websites or via a

combination

of the two

the

Republications ).

15.

The

Article was

subsequently

republished by various

websites

as

alleged in

paragraph 13

above. At

least 7

epublications known

to the

Plaintiff

occurred

between

the

nitial

Publication and

August

20

2014

as listed and

described in Appendix A .

16.

t

was t was

oth

intended

by and

foreseeable

to

Stewart

and

the

AOL

Defendants

that

the

Article

would

receive

widespread

public

attention

and readership. Lindros is a

well-known

public

figure, particularly in

Canada

and the United States and other countries

where

ice

hockey

is

popular.

Furthermore t was

foreseeable to Stewart and

the

AOL

Defendants

that the

libellous content

contained in the

Article

would

cause

Lindros

significant and

permanent

damage

to his personal

reputation.

17.

In

addition,

the

Plaintiff

has suffered

aggravated

damages

as a consequence

of

the

Republications. In

particular,

but without limitation, certain

Republications

alleged,

based upon

the defamatory

statements in

the

nitial

Publication

that

Eric

Lindros

was

apparently an

enormous

bleep]

and commented that

Lindros

angrily tearing up charity

posters

is

a high

point

in

athlete

dickhead

behaviour.

18.

t

reasonably

foreseeable to

Stewart and

the

AOL

Defendants that

further

dissemination

and republication

of

the Article and its contents

would occur following the


9/15

nitia

l

Publ

ication.

he l

ibellous

conten

t

of

th

e Article

an

d

Li

ndros

role as

a publ

ic

figur

e

m de

the

Article

lik

ely

to

attra

ct

a

signi

ficant amoun

t

of

publi

c

attention

and inter

est he

aggrav

ated da

mages

uffere

d by

the Plaintiff

as

a

co

nsequen

ce were

ca

used by

an

d

are

th

e

responsi

bility of t

he

Defend

ants.

1

9. he

de

fendants

are at

law

full

y

respo

nsible

for any

and

all dama

ges suf

fered b

y

the

Pla

intiff fo

r

the n

itial Pub

lication

a

nd

th

e

R

epublica

tions.

20

. In

the

eve

nt

ha

t this claim

is

served outsid

e

of

Ontario,

the

pl

aintiff

relies

upon

the

following

prov

isions

of

rule 17.02

n

supp

ort

o

f

suc

h

serv

ice:

a)

17.0

2 q)

—tort comm

itted

in

Ont

ario;

b) 1

7.02 h)

—d m

ges ust

ained

in Ontario;

c)

17.02(1)

—i

njunctio

ns

in

On

tario;

d)

17.02 0)

—necessary

or

proper

party;

and,

e)

17.02 p)

—per

son

carry

inq

on

bus

iness

in

Ontario

.

21.

Accordi

ngly

the

Plai

ntiff

pl

eads

entit

lement to

the

relie

f

clai

med

in parag

raph 1 of

this

Statem

ent of Clai

m.

he

plaintiff

pro

poses

that

the

action

be tri

ed

in

Toron

to,

Ontar

io.


10/15

-10

Oc

tober

15

,

201

4

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ASSE

LS B

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BLA

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LL

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P

2100

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za

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King

Street

West

Tor

onto,ON

M5

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C

Geoffrey

B.

Shaw

LSUC

:.

26367

Te

l: 416.

869.5

982

Fax:

416.3

50.691

6

gsha

w@casse

lsbroc

k.

o

m

Ti

mothy

Pinos

LSUC

:2

0027U

Tel:

416.8

69.57

84

F

ax:

416

.350.

6903

tpino

s@casse

lsbroc

k.com

Law

yers

or

the

l intif

f


11/15

-11

-

APPE

NDI

X A

(1)

Pu

blica

tion

of

the

Art

icle:

Ti

tle

Au

thor

D

ate Sour

ce

(

a)

Heck

lers

Hoo

ligan

s

an

d the

Stri

ped-Sh

irted

P

aul Stew

art

July

16,

The

Hu

ffing

ton

M

aitre

D

2014

Pos

t

(2

)

Publ

icati

on of

Inte

rnet

l

inks to

t

he Art

icle or

dire

ct

qu

otes

fro

m

the

Articl

e

only:

Ti

tle

A

uthor

D

ate

Sourc

e

(a)

Top

Li

ne: 1

year

s of

ree

age

nt

best

s

worst

s; Allan

Muir

July

1

7,

Sp

orts

llustr

ted

Ice Gir

ls

flap ra

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more

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014

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Lindr

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July

17,

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BC

Sport

s

mak

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R

ound

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Morn

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By

:

Whe

refor

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art

thou

Kelly

Hink

le

Ju

ly 17,

S

B Na

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hockey news

2014

(d)

C

olora

do

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s

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7,

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2014

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Inst

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e or

refe

rence

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e

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cle,

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s

uppl

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Vasquez-Peddie

2014

Blog

(

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14


12/15

Tit

le

(e

)

Fo

rmer

ref:

cut

Lindros no

slack

after

run-in

; ex-tr

ainer

fires

back

f)

Eric Lindros

was s

upposedl

y

a

huge

a

-

hole

as a

rookie

(g)

Teenage

Eric

Lindros

destroyed

a

bunch

of post

ers he

was

su

pposed

to sign

for

char

ity

(h) For

mer N

HL

ef

details

alt

ercations

with f

ormer Fly

er Eric

Lin

dros

i)

A Funny

Story

About

Th

en

-Rooki

e

Eric Lindr

os

B

eing a H

uge

Dickh

ead

j)

Eric

Li

ndros, ex

-Flyer

,

Rang

er once

ang

ered

referee

Paul

St

ewart

by

tear

ing

up

chari

ty poster

s

(k)

Eric Lin

dros

isn t

ha

ving

the

b

est

month

i

n the PR

depa

rtment

I)

Thursd

ay

L

inks

—Acoust

ic

Daft

Punk

m

) HL 2013/

14 Re

gular Season

Thr

ead

(n

)

Eric

Lind

ros Was Kin

d of a D

ick As

a

Youn

gin

(o

) Ex

NHL

ef

shares

story abo

ut Er

ic

Lind

ros

being a

huge er

k

(p)

Retired

NHL

Referee Paul

Stewart

has a

piece in the

Huffin

gton Post

s

lamming

make-u

p

ca

lls,

Two

W

rongs

Don't Mak

e a Righ

t

(q

)

Eric Lindro

s, ex-

Flyer,

R

anger

once

angere

d

refe

ree

Paul

Stewa

rt by

t

earing up

charity

posters

(r

)

Flyers

Equipm

ent Manag

er Jim

Turk

Eve

rs:

Lindro

s Story W

as

NOT

rue

-1

2-

A

uthor

Fox

Sports

Steve

DelVec

chio

Harrison

Mooney

Unknown

Sam

er

Kala

f

C

harles Curtis

John

Chandle

r

Don

ut

Ki

ng

M

essage

B

oard

Sm

y

Antho

ny

Vasque

z-Peddie

Unknown

D1i

1. •

Rob

Gian

none

(s)

My T

ake

On

he

E

ric

Li

ndros

Huffpo

Fillmydelp

hia

Story

That H

as Every

one So

An

ti-Lindro

s

T

hese

Days

t)

Roo

kie Eric Lindr

os

was

a

Hug

e

Unkno

wn

D-Bag

Date Sou

rce

July 17,

F

ox

Sports

20

14

J

uly 18, La

rry

Bro

wn Sport

s

2014

July

16,

Yahoo

Sports

20

14

July 16,

Philly

.com

2014

July 16,

D

eadspin

201

4

Jul

y 16,

Lockerd

ome

via

20

14

nj.com

July 17, T

he

Negade

lphia

2014 Diaries

July

17,

SB Nati

on

2014

July

23,

Uhlinks.

com

201

4

July 16,

B

arstool

Sports

2014

J

uly 17 Ca

noe.ca

2

014

Unknown

Reddit.com/r/hockey

July

1

6,

Flye

rsPhans

2014

J

uly

18

th,

Buzz

onbroad.

com

2014

Ju

ly

17, Liberty C

ity

2

014

July 16

,

Buzz

on Broa

d

2

014


13/15

-13-

Title

Author

Date

Source

(u) My

Take On the

Eric

Lindros Huffpo

Filimydelphia

July 17,

Saltshaker

Story

That

Has

Everyone So

2014

Anti-Lindros

These Days

(v)

Flyers

Equipment

Manager

Claims

Jim

Adair

July 18, Crossing Broad

Eric

Lindros

was

Not

a

Huge

Jerk

2014

When

He

was

Young

(a)

Eric

Lindros, ex-flyer, Ranger

once nj.com

July

16, NJ.com

angered referee

Paul

Stewart

by 2014

tearing up

charity

(4)

Publication of

Internet

links, including

links

with commentary, o other

commentary

about the

Article:

Title

Author

Date

Source

(b)

Thursday's

A.M.

Hot

Clicks:

Andy

Gray

July

Sports

Illustrated

EI

Paso

Unveils

Chihuahua 17,

Linked to: Yahoo Sports: Teenage

2014

Eric

Lindros destroyed

a

bunch of

posters he was supposed to sign for

charity.

(c)

Hitler's

`appendicitis

attack';

Babcock scaring

away

UFAs?; learning

`stupid

easy'

ancy

stats(Puck

Headlines)

(d)

Teenage

Eric

Lindros

destroyed

a

bunch

of

posters

he

was supposed

to

sign for

charity

(e) Eric

Lindros,

ex

-Flyer,

Ranger

once angered

referee Paul

Stewart by

tearing

up

charity

posters

(f)

Eric Lindros was

a turd when Unknown

he was a

rookie

Jen

Neale July

Yahoo Sports

Linked to:

Buzz

on

Broad: Flyers

2014

Equipment

Manager Jim

Turk Evers:

Lindros Story

was

NOT

True

July FS Network

16,

Linked

to:

Yahoo

Sports:

Teenage

2014

Eric

Lindros

destroyed

a

bunch

of

Unknown

posters he was

supposed

to sign for

charity.

July Hockey

or

Die

16,

Linked to:

NJ.com Eric

Lindros,

2014

ex-Flyer, Ranger

once

angered regeree

Paul

Stewart by

tearing

up

charity

posters

Also Linked

to:

Deadspin: A

Funny

Story About Then-Rookie Eric

Lindros

Being

a

Huge

Dickhead

July HFBoards

16,

Linked to:

Deadspin: A

Funny Story

2014

About

Then-Rookie

Eric Lindros

Being a

Huge Dickhead

Charles

Curtis


14/15

-14-

Title

(g)

Eric

Lindros,

ex

-Flyer,

Ranger

once angered

referee Paul

Stewart

by

tearing

up

charity

posters

Author

Date

Charles July

Curtis

16,

2014

Source

(h)

Flyers

equipment manager

Unknown

mentioned in

Paul

Stewart

article

about Eric Lindros

says

story is

bullshit

Veooz.ca

Linked to:

NJ.com

Eric

Lindros,

ex

-Flyer,

Ranger

once

angered

referee

Paul Stewart

by

tearing

up

charity

posters

Reddit.com/r/hockey

Linked to: buzzonbroad.com, Flyers

Equipment

Manager

Jim `Turk'

Evers:

`Lindros

Story

Was

NOT rue"'

(i)

Teenage Eric

Lindros

Harrison

July

Yahoo

Sports

—Puck

Daddy —

destroyed abunch

of

Mooney

16,

Linked

to: Deadspin.com, A Funny

posters

he

was

supposed

to 2014

Story

About

Then

-Rookie Eric

Lindros

sign

for charity

Being A

Huge Dickhead"

(j) NHL

News and

Links

—

Mike July

Fansided

Quick

Shifts:

July

17th

Majeski 17,

Linked

to:

Puck

Daddy

Teenage Eric

Edition

2014

Lindros

destroyed

a

bunch

of

posters he

was supposed to sign for

charity

(k) A

Funny

Story

about

Unkown July

Reddit.com/r/hockey

Then

-Rookie Eric

Lindros

16,

Linked

to:

Deadspin

"A

Funny Story

Being

a Huge

Dickhead

2014

about Then

-Rookie Eric

Lindros

Being

a

Huge

Dickhead'

(I)

A

Funny Story

about

Samer

July

Veooz

Then

-Rookie

Eric

Lindros

Kalaf 16,

Linked to: Deadspin "A Funny Story

Being a

Huge

Dickhead

2014

about Then-Rookie Eric Lindros Being a

Huge

Dickhead'

m)

aul

Stewart

article

—

Blog

July

Phillysportsforums.com

Discussing

his

irst

16,

Linked

to:

Deadspin "A Funny Story

experience

with Eric

Lindros

2014

about

Then

-Rookie

Eric Lindros

Being a

Huge Dickhead':

(n) A high point

in

athlete Samer

July Facebook.com

Via Deadspin

dickhead behavior

Kalaf 16,

Linked

to: Deadspin "A Funny

Story

2014

about Then

-Rookie Eric

Lindros

Being

a

Huge Dickhead':

(o)

Never

heard this Lindros Unknown July Sportshoopla.com

Story

16,

Linked to:

Deadspin "A Funny Story

2014

about

Then

-Rookie

Eric

Lindros

Being a

Huge

Dickhead':

(p)

Story

about

Lindros,

Unknown

July HF

Boards

including

his time

in Blue

16,

Linked to:

Deadspin "A Funny

Story

2014

about

Then-Rookie Eric Lindros

Being a

Huge

Dickhead'


15/15

eric lindros - statement of claim

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