The URL can be used to link to this page

2014-151-Minutes for Meeting March 05,2014 Recorded 3/17/2014 DESCHUTES COUNTY CLERK Vd 2014.151 NANCY COMMISSIONERS' JOURNAL 03/17/2014 08;11;33 AM !L1VJ1IJJJiIIllIIlUIIIDhlII Do not remove this page from original document. Deschutes Count y Clerk Certificate Page c qe 4 vT7s Q e Ut 0 IOLA Deschutes County Board of Commissioners 1300 NW Wall St., Suite 200, Bend, OR 97701-1960 (541) 388-6570 - Fax (541) 385-3202 - www.deschutes.org MINUTES OF WORK SESSION DESCHUTES COUNTY BOARD OF COMMISSIONERS WEDNESDAY, MARCH 5, 2014 Present were Commissioners Tammy Baney, Anthony DeBone and Alan Unger. Also present were Tom Anderson, County Administrator; Erik Kropp, Deputy County Administrator; and,for a portion of the meeting, Laurie Craghead, County Counsel; Ed Keith, Forester; Chris Doty, Road Department; Judith Ure, Administration; and eight other citizens, including Angela Lee-Mandlin, Bruce White, Carly Moore and Marcus Tiktin of the Mock Trial Group; and a representative of KTVZ TV. Chair Baney opened the meeting at 1:30 p.m. 1. Mock Trial Group Presentation — Classroom Law Project. Student Marcus Tiktin, a junior at Summit High School, said he has been involved in this group since he was a freshman. He explained what a mock trial group does. They select a criminal or civil case to use as a test case, with the assistance of an attorney or judge. At Summit High, this is extracurricular class. Student Carly Moore is a freshman at Bend High School, where this is also an extracurricular activity. She finds it amazing to see how a trial works and appreciates her instructor, Lillian Quinn. Mr. Tiktin said they started practicing on this three months ago. The competition was last weekend. They are assigned three cases and it is randomized as to who gets which side at trial. His group moves to the State competition in a couple of weeks along with the home school group. Seven teams competed. He said that the biggest part for him was the public speaking piece. He gives the closing statement. Minutes of Board of Commissioners' Work Session Wednesday, March 5, 2014 Page 1 of 5 Ms. Moore stated that the courtroom setting was a great experience. She thanked the Board for helping with the costs involved. Her school does not charge the students. Mr. Tiktin said students at Summit have to pay towards supplies and materials, and transportation if they go to the State event. He found this experience teaches three things: leadership skills, speaking skills and learning about the law and perhaps a future career path. Commissioner Unger stated that Redmond has a student court, and perhaps they could investigate this since they do not do this in Bend. They decide on cases that involve other students that got into trouble. Bruce White invited the Commissioners to be involved with mock trial next year as possible judges. 2. Discussion regarding Adjustments to the County's Weed Ordinance. Chair Baney wanted to start with the emergency clause. Commissioner Unger noted that this has been an issue for years. Commissioner DeBone added that he can see a need to have this in place for spring when weeds sprout. It is probably too late for that this year. Commissioner Unger said that this is for those few people who cause problems. The Board wants to move forward without the emergency clause. In regard to the separation of power, they could have the Sheriff handle part of this. Community Development does enforcement to a point. There is some benefit having someone with a badge show up. However, the Sheriff may not want staff spending time doing this type of thing. Mr. Anderson stated that the Sheriff's Office has substantial experience doing this for CDD. In most cases, if the Sheriff's Office does this, they start with a warning or even just a conversation. Tom Wells, a law enforcement technician, does most of this and works with people at a personal level. Usually this results in compliance. Minutes of Board of Commissioners' Work Session Wednesday, March 5, 2014 Page 2 of 5 In regard to cleaning equipment, the State does not provide a definition. It should be defined so it can be approached in a uniform way. Pressure washing is not always practical. They can remove the `how to do it' part and just show an expectation of the equipment being cleaned. Ms. Craghead reiterated that this is in the ordinance now and has always been there, and it is in State law if the equipment moves onto public roadways. Commissioner Unger said that this is an educational process and most will want to comply. Chair Baney added that certified weed free crops are very important to some. Ms. Craghead noted that a farm could actually be quarantined through the Department of Agriculture, if there are too many harmful weeds there. This is in State statute and already available to the County. Commissioner Unger would like the Ordinance and Orders easy for the public to access. Mr. Keith stated that State statute is posted right next to the Ordinance. The Orders refer to Statute. Chair Baney said that she looked this up on the website and found it was user-friendly. Ms. Craghead stated that the Orders establish the District, refer to State statute and appoint the Road Department Director as weed control inspector. This has been spelled out in the new Ordinance. By Statute, County legal counsel cannot represent the County unless the other party has counsel. The Weed Control Inspector has to contact the District Attorney to go further. The compliance window was a recommendation from the Weed Advisory board. They need to act in a short timeframe before the weeds go to seed. They moved up the time to two to ten days rather than the two to twenty days in the State law. This can mirror statute, but it may not make a difference. As to whether this should apply to agricultural lands only, the entire County is a Weed Control District, and each parcel impacts the whole. State law does not allow selective enforcement. This is not an effective way to control weeds and it impacts property values even in residential areas. There should be the same standard for all lands. The County has no jurisdiction within the city limits or on State or federal lands. Minutes of Board of Commissioners' Work Session Wednesday, March 5, 2014 Page 3 of 5 Ms. Craghead said that they cannot be less restrictive than State law, so they cannot exclude any lands. This goes well beyond the agricultural impacts. The Board felt that staff recommendations on this are appropriate. In regard to education, financial assistance and voluntary compliance, this is already incorporated and is the desired outcome. This is clear in the code enforcement policy. Questions regarding using chemicals came up. There is no change in this. There is no mandate on the use of approved chemicals or other methods. There are a multitude of approaches that are feasible. The property owner and weed inspector can discuss the best methods on a case-by-case basis. Integrated vegetation management principles can be encouraged. This can be added. In regard to County properties, this applies to all lands including County-owned. and lands over which the County has jurisdiction. Chair Baney asked if there is a work plan for the County to address its own needs. Mr. Keith said there was a plan drafted previously through Dan Sherwin, but it needs refinement and updating annually. Some lands have been foreclosed and came to the County in poor condition. Ms. Craghead noted that Property & Facilities did work on cleaning up these properties, but it changes continually. Chair Baney said there needs to be a coordinated effort. Mr. Keith stated that Property & Facilities normally would contract with people to get this done. It all needs to be captured in a plan. The Commissioners agreed this covers their concerns, and asked for a revised draft for deliberation. The oral and written record is closed. Ms. Craghead observed that a public hearing was not even required, but the Board wanted to reach out to the public. The Board allowed Judy Forsythe to speak. She asked if the monies received go to the State. Mr. Anderson said that money generated from any kind of citation, whether a speeding ticket or something under Code, goes to the State. Some comes back based on volume, but what people are paying is the Courts. Ms. Forsythe said that the Weed Board misunderstood this. She asked if the property owners are on farm deferral, do they lose this if they do not comply. Mr. Anderson stated that the Assessor reviews deferrals of all kinds, and is the best resource for this explanation. Minutes of Board of Commissioners' Work Session Wednesday, March 5, 2014 Page 4 of 5 3. Other Items. The Board went into executive session at 2:20 p.m., under: • Executive Session, under ORS 192.660(2)(b), a Personnel Issue • Executive Session, under ORS 192.660(2)(e), Real Property Negotiations Being no further items discussed, the meeting adjourned at 2:20 p.m. IA DATED this f Day of 2014 for the Deschutes County Board of Commissioners. Tamy ey, Chair Anthony DeBone, Vice Chair ATTEST: 05744ifAA 60(-1A, Alan Unger, Commissioner Recording Secretary Minutes of Board of Commissioners' Work Session Wednesday, March 5, 2014 Page 5of5 Q ee Deschutes County Board of Commissioners 1300 NW Wall St., Suite 200,Bend, OR 97701-1960 (541)388-6570 -Fax (541) 385-3202 -www.deschutes.org WORK SESSION AGENDA DESCHUTES COUNTY BOARD OF COMMISSIONERS 1:30 P.M., WEDNESDAY, MARCH 5, 2014 1. Mock Trial Group Presentation—Classroom Law Project—Angela Lee- Mandlin, Mock Trial Competition Regional Coordinator 2. Discussion regarding Adjustments to the County's Weed Ordinance—Ed Keith, Laurie Craghead 3. Other Items. Executive Session, under ORS 192.660(2)(b), a Personnel Issue PLEASE.NOTE:At any time during this meeting,an executive session could be called to address issues relating to ORS 192.660(2)(e),real property negotiations;ORS 192.660(2)(h),litigation;ORS 192.660(2)(d),labor negotiations;or ORS 192.660(2)(b),personnel issues;or other issues under ORS 192.660(2),executive session. Meeting dates,times and discussion items are subject to change. All meetings are conducted in the Board of Commissioners'meeting rooms at 1300 NW Wall St.,Bend,unless otherwise indicated. Ifyou have questions regarding a meeting,please call 388-6572. Deschutes County encourages persons with disabilities to participate in all programs and activities. This event/location is accessible to people with disabilities, If you need accommodations to make participation possible,please call(541)388-6571,or send an e-mail to bonnie.baker a,deschutes.org. • 1 a a, a 1 ,„ v 'C7 r cd ®1 ' b �+ 'a3 o 1 s - j 6 .E el J 1 M 01 r a c K1 ti • n \D � 0- ,r a. _ T v1 I d.,,,, .._ .1 st \._ Et,- ,-' ,i: rn 4 o Q ab r) tvA w u C 0) c, 00 Q P • v d1 v C "1 ` r I Ll ro 4''' v c s -Ne `Q z .) :1\'‘.7c ' O 0. - a .r �•B V a) co • IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR CHINOOK COUNTY MIA PEREZ,a minor, by and through her ) ) Parent,CASEY PEREZ ) Case No: MT2013-2014 Plaintiff ) v. ) COMPLAINT SHANNON DEMPSEY,JORDAN ) DEMAND FOR JURY TRIAL ) REDDICK,and RUBICON SOCCER CLUB ) Defendant ) COMPLAINT FOR NEGLIGENCE COMES NOW the Plaintiff,MIA PEREZ, by and through her parent and guardian,CASEY PEREZ, and respectfully states to the Court and alleges as follows: JURISDICTION AND VENUE 1. That at all times mentioned,Plaintiff Mia Perez,a minor,was and is a resident of Chinook County, State of Oregon. Casey Perez,parent and lawful guardian of Mia Perez,was and is a resident of Chinook County,State of Oregon. 2. At all times mentioned,Defendant Shannon Dempsey was and is a resident of Chinook County, State of Oregon. 3. At all times mentioned,Defendant Jordan Reddick was and is a resident of Chinook County, State of Oregon. 4. Defendant Rubicon Soccer Club, Inc. is incorporated in the State of Oregon with its principal place of business being in Chinook County,State of Oregon. 5. All of the acts complained of in this complaint occurred in Chinook County, State of Oregon.Therefore, venue is proper in this court. 6. In the aggregate,Plaintiff's claims exceed $50,000 exclusive of interest and costs,and therefore this Court has original jurisdiction. FACTS 7. Prior to and on the date of December 2,2012,Plaintiff Mia Perez was a member of the Under-17 Rubicon Soccer Club Premier Girls' soccer team,coached by Defendant Dempsey. 8. On Monday, November 26,2012,. Plaintiff Mia Perez struck her head on the ground during soccer practice. She seemed shaken up enough for Defendant Dempsey to require Plaintiff to sit out for the remainder of practice. 9. Defendant Dempsey did not inform Casey Perez,Plaintiff's parent,of the incident in Monday's practice,nor did the Defendant suggest that Plaintiff Mia Perez be checked out by medical personnel for a possible concussion. 4 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 10. On Sunday,December 2, 2012,Plaintiff Mia Perez suffered a blow to the head during the first half of the College Showcase tournament soccer game. Defendant Dempsey did not remove Plaintiff Mia Perez from the game at that time to check on her but,instead, kept Plaintiff Mia Perez in the game until halftime. 11. Defendant Dempsey did not ask Plaintiff Mia Perez about any possible concussion symptoms during halftime. 12. Defendant Dempsey put Plaintiff Mia Perez into the game at the beginning of the second half. About 15 to 20 minutes later,Plaintiff Mia Perez was tripped while dribbling the ball toward the goal. Plaintiff Mia Perez fell to the ground, striking her head hard when she landed. 13. Plaintiff Mia Perez was knocked unconscious by the force of the blow to her head. She was transported to the emergency room at Chinook County Hospital,where she regained consciousness more than an hour later. 14. Plaintiff Mia Perez suffered a serious concussion from the blow to her head. She continues to suffer from post-concussion syndrome months after this incident. COUNT ONE 15. The Plaintiff hereby adopts and incorporates by reference paragraphs 1 through 14 as if fully set forth herein. 16. At all relevant times,Defendant Shannon Dempsey had a duty of care toward the Plaintiff to supervise,monitor,regulate,and take all reasonable and appropriate steps to minimize the risk of injury to the Plaintiff from her participation in soccer practices and games. 17. Beginning on Monday,November 26,2012,and proceeding through Sunday, December 2,2012,Defendant Dempsey breached his/her duty to Plaintiff by carelessly and negligently ignoring clear symptoms of concussions which the Plaintiff exhibited throughout that period. 18. By failing to remove Plaintiff Mia Perez from practices and the College Showcase game until the Plaintiff had been cleared to play by a physician knowledgeable in the diagnosis and treatment of concussions,Defendant Dempsey created a foreseeable risk of harm to Plaintiff Mia Perez. In doing so, Defendant Dempsey directly and proximately caused the harm which Plaintiff Mia Perez suffered from repeated concussive events during the time in question. 19. Plaintiff Mia Perez has sustained past medical expenses and will incur future medical expenses and costs associated with the harm suffered and disability referenced above. 20. Plaintiff Mia Perez has in the past experienced,continues to experience,and may in the future suffer from an assortment of problems associated with the harm described above,including but not limited to,headaches,dizziness,loss of memory,depression,cognitive dysfunction, diminished educational achievement,employment impairment,limitations in physical activities,and loss of the pleasures of life. 21. As a result of the foregoing,Plaintiff Mia Perez has suffered damages and will in the future suffer damages caused by the negligence of Defendant Dempsey. COUNT TWO 22. Plaintiff hereby adopts and incorporates by reference all prior paragraphs of this Complaint as if fully set forth herein. 5 CLASS Room I,AW PR()/1 CT Oregon High School Mock Trial Competition www.classroomlaw.org 23. At all relevant times,Defendant Jordan Reddick,as the Director of the Rubicon Soccer Club,had a duty of care to Plaintiff to supervise,educate,monitor,and provide reasonable information and rules to club players,parents,and coaches,to minimize the risk of injury to the players. 24. Defendant Jordan Reddick was careless and negligent by breaching the duty of care to players and coaches both generally and in the following particular respects: a. Failing to educate players,parents,and coaches concerning symptoms of a possible concussion; b. Failing to warn of the risk of unreasonable harm or possible long-term complications resulting from repeated concussions; c. Failing to implement rules and protocols to adequately address the dangers of repeated concussions and to implement a medically-sound return-to-play policy to minimize long-term chronic cognitive problems; d. Other acts of negligence or carelessness which may materialize during this civil action. 25. Because of the negligence and breach of duty of Defendant Reddick,Plaintiff Perez has suffered damages and will in the future suffer damages as described in the foregoing paragraphs incorporated herein. COUNT THREE 26. Plaintiff Mia Perez hereby adopts and incorporates by reference all prior paragraphs of this Complaint as if fully set forth herein. 27. Defendant Rubicon Soccer Club,as the organization under which Plaintiff Mia Perez engaged in the sport of soccer,had a duty of care to establish reasonable rules and regulations and return-to-play protocols to minimize the risk of injuries to players in the club. 28. . By failing to gather and disseminate specific information regarding prior player concussions on club medical waiver forms; failing to establish reasonable rules and regulations to educate players,parents,and coaches about the symptoms and risks of repeated concussions; and failing to establish clear and medically sound policies for safe return-to-play,Rubicon Soccer Club breached its duty of care to Plaintiff. 29. Because of the negligence and breach of duty of Rubicon Soccer Club,Plaintiff has suffered damages and will in the future suffer damages as described in the foregoing paragraphs incorporated herein. WHEREFORE,Plaintiff requests judgment for the following: 1. Judgment against Defendants for compensatory damages in an amount to be determined by a jury; 2. Payment of the costs resulting from this action to be taxed against the Defendants; 3. Such other and further relief as this Court may deem just and proper. Plaintiff requests a jury trial on all issues. 6 CLASSROOM LAW PRojrci Oregon High School Mock Trial Competition www.classroomlaw.org Respectfully submitted,this the 1st day of August,2013. Alex Morgan Alex Morgan,Esq. Attorney at Law 1111 Thorn Way Rowe,Oregon 97205 7 CLASSROOM l.Aw PRo c I Oregon High School Mock Trial Competition www.classroomlaw.org IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR CHINOOK COUNTY MIA PEREZ,a minor, by and through her ) ) Parent,CASEY PEREZ ) Case No: MT2013-2014 Plaintiff ) v. ) ANSWER SHANNON DEMPSEY,JORDAN ) DEMAND FOR JURY TRIAL ) REDDICK,and RUBICON SOCCER CLUB ) ��.Defendant ) ANSWER COMES NOW the Defendants, SHANNON DEMPSEY,JORDAN REDDICK,and RUBICON SOCCER CLUB,INC.,and respond to the Plaintiff's Complaint as follows' ,1URISDICTION AND VENUE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Defendants admit that the aggregate damages claimed by the Plaintiff exceed $50,000 but deny that the damages are due to negligence on the part of the Defendants.Nonetheless, Defendants do not contest the venue or jurisdiction of Chinook County Circuit Court. FACTS 7. Admitted. 8. Defendants Jordan Reddick and Rubicon Soccer Club lack sufficient knowledge to form. a belief as to the truth of the allegations in paragraph 8,and thus it is denied. 9. Defendants Jordan Reddick and Rubicon Soccer Club lack sufficient knowledge to form a belief as to the truth of the allegations in paragraph 9,and thus it is denied. 10. Defendants lack sufficient knowledge to form a belief as to the truth of the first allegation in paragraph 10,and thus it is denied.The second allegation is admitted. 11. Defendants Jordan Reddick and Rubicon Soccer Club lack sufficient knowledge to form a belief as to the truth of the allegations in paragraph 11,and thus it is denied. 12. Admitted. 13. Admit Plaintiff Mia Perez was nonresponsive during the second half of the December 2, 2012,. game and was transported away from the field by emergency medical personnel. Except as admitted, Defendants lack sufficient knowledge to form a belief as to the truth of the allegation in paragraph 1,and thus it is denied. 14. Defendants lack sufficient knowledge to form a belief as to the truth of the in paragraph 13,and thus it is denied. 8 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw-org COUNT ONE 15. Defendants' responses to Paragraphs 1 — 14 are incorporated herein by reference. 16. Admitted. 17. Denied. 18. Denied. 19. Defendants lack sufficient knowledge to form a belief as to the truth of the allegations in paragraph 19,and thus it is denied. 20. Defendants lack sufficient knowledge to form a belief as to the truth of the allegations in paragraph 19,and thus it is denied. 21 . Denied. COUNT TWO 22. Defendants' responses to all prior paragraphs of the complaint are incorporated herein by reference. 23. Admitted. 24. Denied in general and as to all allegations in subparagraphs (a)—(d). 25. Denied. COUNT THREE 26. Defendants' responses to all prior paragraphs of the Complaint are incorporated herein by reference. 27. Denied. 28. Denied. 29. Denied. FIRST AFFIRMATIVE DEFENSE 30. Defendants assert the defense of comparative negligence. Plaintiff failed to exercise reasonable care for her own safety and thereby contributed to her own injury in one of more of the following ways: (1) by re-entering the soccer game after injuring her head,(2) by failing to notify her coach of her concussive symptoms,and (3) in such further ways as may be shown by evidence in this case. WHEREFORE,Defendants pray the following from the Court: 1. That Plaintiff Mia Perez recover nothing from Defendants Shannon Dempsey,Jordan Reddick,and Rubicon Soccer Club, Inc.; and 2. Such other and further relief which the Court may deem just and proper. Defendants request a jury trial on all issues. Respectfully submitted this the 31st day of August,2013. Chr%s 5%hc/a;r Chris Sinclair,Esq.,Attorney at Law 12012 Winner Cir. Rowe,Oregon 97205 9 Ci ssi-toOM LAW PROM?c.;f' Oregon High School Mock Trial Competition www.classroornlaw.org IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR CHINOOK COUNTY MIA PEREZ,a minor, by and through her ) ) Parent,CASEY PEREZ ) Case No: MT2013-201.4 Plaintiff ) v. ) STIPULATIONS SHANNON DEMPSEY,JORDAN ) REDDICK,and RUBICON SOCCER CLUB ) Defendant ) STIPULATIONS 1. Alf exhibits included in case materials are authentic. No objections to the authenticity of exhibits will be honored. 2. All signatures on Witness Affidavits and other documents are authentic. if asked,a witness must acknowledge signing the document(s) and must attest to the content of the documents(s) and the date(s) indicated thereon.The Witness Affidavits are deemed to be given under oath or affirmation. 3. The trial is bifurcated and the only issue to be determined in this trial is liability.The amount of damages to be awarded, if any,will not be at issue in this proceeding. 4. The Acute Concussion Evaluation (ACE) report is admissible without further foundation. No hearsay objection to this document will be allowed. 5. Before trial,the Court denied the Defendants' motion to dismiss the lawsuit on the grounds that Plaintiff waived and released her claims through her parent's execution of the Medical Consent/Waiver of Liability and Release,dated June 2,2012. In its ruling,the Court determined,as a matter of law,that the waiver and release of liability was not enforceable against Plaintiff. Alex Morgan C.hr%s 5%nc/ar Alex Morgan,Esq. Chris Sinclair,Esq. Attorney at Law Attorney at Law 1 11 1 Thorn Way 12012 Winner Cir. Rowe,Oregon 97205 Rowe,Oregon 97205 10 CLASSROOM 1...'\W PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org E. Witness Statements 2 3 Affidavit of Casey Perez 4 5 My name is Casey Perez; I am a 42 year old single parent living in Rowe,Oregon. I 6 attended Oregon State University 20 years ago,and after I graduated,I married my college 7 sweetheart and began working as a graphic design artist at a small marketing company in Rowe. 8 It doesn't pay a lot but I love what I do. We were living the American dream.That is, we were 9 until my spouse died eight years ago in a terrible car accident, leaving me to raise our daughter 10 Mia alone:It was such a shock, I could hardly function, but I had to pull myself together for 11 Mia's sake. I tried to find things we could do as a family,so I started volunteering with her 12 Brownie scout troop and signed her up for sports camps at the Y. Mia was amazingly fast and 13 very coordinated,and soon she was the star of her basketball,track,and soccer teams. It was 14 great to see her moving past her grief and doing something she loved. 15 16 At the time of Mia's injury on December 2,201.2,Mia was 16 and a junior at Rowe High 17 School. Mia has always been crazy about soccer; she dreamed of playing in the pros like her 18 idols Cindy Parlow and Mia Hamm. She watched soccer every chance she could get,and she 19 begged me to take her to college games at University of Portland not far from here. So when she 20 made it onto the top competitive soccer team with the Rubicon Soccer Club at age 13, Mia was 21 thrilled. She knew that many Rubicon players have earned soccer scholarships to college, so it 22 seemed like the first step to reaching her dreams. I had to fill out a pile of paperwork to sign her 23 up,although it surprised me that she wasn't required to get a physical or give any real 24 information about past medical history or injuries; they just wanted to know if she'd had a 25 tetanus shot or suffered from allergies. 26 27 The club fees are expensive,and then you have all the costs of traveling to tournaments 28 and getting expensive cleats and uniforms. I couldn't afford it all on my salary so I had to start 29 working a second job in the evenings. It meant I had to find carpools to get Mia to practices,and 30 I couldn't watch all of her games like I used to do. But when I saw her joy as she made the Rowe 31 High School varsity team as a freshman,I felt like the sacrifice was worth it. She even got to 32 wear jersey#9,just like Mia Hamm. Soon she was starting every game as a forward—a 33 "striker"—and she quickly became the leading scorer. 34 35 When Mia got her license on her 16th birthday,it was a relief to know she could drive 36 herself to practices and games and I didn't have to keep asking favors of other parents. But I did 37 arrange my schedule so I could come to really important games,like when we played our 11 CT.ASSROOM LAW PRO/h: 71' Oregon High School Mock Trial Competition www.classt-nornlaw.org 1 school's biggest rival,Carthage High School,in the first playoff game last May. Mia was really 2 excited about the game; she thought Rowe might defeat Carthage for the first time ever,and if 3 they could get past Carthage, maybe they could go all the way to state finals. At halftime we 4 were leading 2—0,and Mia had scored one goal and assisted on the other. But about midway 5 through the second half,Mia collided with a defender when they both went up for a header,and 6 Mia went down hard. She looked woozy when she got up, so her coach,Tobin O'Reilly, pulled 7 her out right away. Coach O'Reilly is great; s/he wants to win, but not at any cost. When. 8 Carthage scored,I saw Mia asking to go back in the game,but Coach O'Reilly wouldn't let her. 9 The team managed to hold off Carthage and won,2-1! The whole team was jumping up and 10 down with excitement,although Mia mostly stayed still and just hugged her teammates. 1I 12 After the game Coach O'Reilly told me that I should take Mia to the doctor the next day, 13 since she was still a bit woozy and complaining of a headache. Mia appeared to feel completely 14 fine the next morning but we went to our physician,Dr. Rick Mueller,first thing anyway.After 15 examining her,he said that Mia had a mild concussion. He told her she needed to rest and avoid 16 strenuous mental and physical activities,including soccer,for a week,then we should come back 17 for a follow-up visit. I still have the instruction sheet he gave us after her visit. 18 19 Mia rested just as Dr. Mueller ordered. But without her,the school team lost the next 20 playoff game. Mia felt really bad about that but Coach O'Reilly and all her teammates told her 21 not to worry,they'd have another chance the next year. Since soccer was finished for the season 22 and Mia said she felt fine, we never did go hack for the follow-up visit with Dr. Mueller. It just 23 didn't seem necessary since the Rubicon club soccer tryouts were a month away. 24 25 Mia did well in tryouts and stayed on the top Under-17 Rubicon team with Coach 26 Michelle Foudy,although some of her good friends got dropped down to the second team. When 27 I turned in all of Mia's paperwork, I made sure to write down on the Medical Waiver form that 28 Mia had suffered a concussion in her school game on the line marked "List any unusual health 29 information" since the form does not ask for such information specifically. 30 31 Mia was really happy when her Rubicon practices started back up. Surprisingly,Mia's 32 team had a new coach,Shannon Dempsey. At the first team meeting,Coach Dempsey told the 33 girls that Coach Foudy left to care for her dad, who had been diagnosed with cancer. Mia and her 34 teammates were sad for Coach Foudy,but they were impressed to hear that Coach Dempsey had 35 played in college on a full soccer scholarship and had turned down an offer to play in the pros. 12 CLASSROOM 1..AW PRO1l-CT Oregon High School Mock Trial Competition www.classruomlaw.org 1 As the top team in the Premier division,Mia's Rubicon club team was getting lots of 2 attention from college coaches. In fact,the girls were so confident of winning their division that 3 they made team shirts with the slogan"Rubicon Soccer: We Came, We Saw, We Conquered." 4 Mia was still the leading scorer,and she was playing her best soccer ever. Coach Dempsey 5 stressed hard work and instituted strict rules,and it all seemed to pay off when the team finished 6 the season undefeated. When the team signed up for a college showcase tournament in early 7 December,Mia knew it was her chance to be seen by top college coaches from all across the 8 country: UPS,UCLA and Stanford,and even University of North Carolina and Duke. I made 9 sure to work extra evening shifts early in the week of the tournament so I could watch her play 10 that weekend. I knew how important this opportunity was for Mia; she had to get a scholarship to 11 have any hope of attending a top-tier university. 12 13 The tournament was on the weekend. I didn't get to talk with Mia very much that week 14 because of my work. When I saw her for a few moments on Tuesday evening,she did seem kind 15 of quiet and stressed, but I knew she was feeling pressure to do well in the tournament. She was 16 already in bed when I got home from work on Wednesday,and I didn't get to talk with her much 17 on Thursday morning. On Thursday evening when I got home she still seemed stressed,so I tried. 18 to tell her to relax and play her game,and everything would be fine. She kind of paused and 19 looked at me like she wanted to say something,but then she just said she was going to bed. On 20 Friday morning she slept through her alarm and I had to wake her up for school, which surprised 21 me because Mia was always up before her alarm. I asked if she was getting sick but she said she 22 was okay,she was just tired from all of the tests she'd had that week.I told her again to relax and 23 said I would meet her at the game that afternoon. 24 25 I got to the game after it had already started. I noticed lots of coaches on the sidelines, 26 taking notes on clipboards; I even saw some of them pointing out Mia. Mia was out on the field 27 in her usual position of striker but I noticed she didn't seem to be running as hard as usual. I 28 figured that maybe she was getting sick after all,and I hoped she'd be able to shake it off and 29 play well.With about 10 minutes to go in the first half,Mia tried to head the ball to score on a 30 corner kick,and it looked like she took an elbow to the head. She seemed a bit shaken,and co- 31 captain Megan Cheney even came over to check on her. But Coach Dempsey didn't seem to care 32 and in any case,s/he didn't pull Mia out. Soon it was halftime, with the score tied 0-0. 33 34 Mia started the second half,and she seemed to be a bit better after the short break for 35 halftime. In fact, she almost scored a goal about 5 minutes in,but the goalkeeper made a great 36 save. About 10 minutes later a teammate passed the ball to Mia right outside the penalty box,and 13 CL\ssRoOM LAW PRl)lis(.°1 Oregon High School Mock Trial Competition www.classroomlaw_org 1 Mia started dribbling toward the goal.All of a sudden a defender made a hard tackle on the ball. 2 and Mia lost her balance and crashed on the ground,hitting her head. I waited for her to get up, 3 but she just lay there.The referee stopped play immediately and Coach Dempsey ran out on the 4 field. Mia still wasn't moving and,next thing I knew,I saw the field marshal and athletic trainer 5 run out on the field. I was in shock; then I ran out on the field. Coach Dempsey said to me,"I'm 6 so sorry,I'm so sorry; I knew Mia wasn't feeling well.I can't believe she got hurt." I saw that 7 Mia was unconscious,and I heard them call for the ambulance which was at the tournament to 8 come get Mia and take her to the ER. Of course I rode with them,although I don't remember 9 much of what went on. All I kept thinking was "please,let her be okay; I can't lose her,too." I0 11 At the hospital,the doctors ran tests and they said Mia had a concussion. She finally 12 woke up about an hour after we got there but she seemed really "out of it."They kept her 13 overnight for observation,and they talked with both of us about what to watch for and how it 14 might be days or even weeks before Mia fully recovered.They said that in a small percentage of 15 cases, the person can have serious,long-lasting problems. Of course, we never thought that 16 would happen to Mia, but our worst fears have come true. 17 18 Mia started having serious migraines a few days after she was discharged. She was 19 incredibly sensitive to light and noise,and she was moody and depressed. She couldn't 20 concentrate and had trouble remembering things. I kept her out of school since it was almost the 21 winter break and I hoped she would get better before the new semester started. But she didn't. In 22 fact, she hasn't been able to return to school since the injury. She still has intense headaches, 23 dizziness,and even nausea,even though it's over a year later. Because light still bothers her, we 24 have to keep our house dark,with dim blue lights or candlelight. It's so bad that she can't come 25 to testify in court,because the stress is just too much for her. 26 27 Mia's taking one class online now,but that's all she can handle. She won't be able to 28 graduate with her class this spring,and she certainly won't be going to college on a soccer 29 scholarship or playing in the pros. Her life has been completely changed,and the doctors don't 30 know if she'll ever fully recover. And I worry about her future. I mean,you read now about these 31 NFL football players who are getting early dementia,and I wonder,is that going to be Mia?Will 32 she ever go to college or be the person she could have been? 33 34 I don't fault the game of soccer. Mia loves soccer,and obviously millions of people play 35 it without these types of problems. But I do fault Coach Dempsey and the Rubicon Soccer Club 36 Director Jordan Reddick. After Mia woke up in the hospital, she told me that she took a hard hit 14 CLAssR(.)UM l,Aw PRolECI Oregon High School Mock Trial Competition www.classroomlaw.org l to the head in practice on Monday before the tournament but Coach Dempsey never did anything 2 about it,and certainly didn't inform me about it. High schools have all these protocols in place to 3 train coaches about concussions and make sure students aren't put in danger,but the Rubicon 4 Soccer Club doesn't do anything to train coaches about concussions. Sure,the club talks about 5 good nutrition and all,but playing with a concussion can ruin a player's life. 6 7 I know I signed a waiver saying I can't hold the club accountable for injuries but, 8 thankfully,the judge ruled that the waiver doesn't keep Mia from suing them.And I wrote right 9 on the waiver form that Mia had suffered a concussion at school so that the Rubicon coach 10 would know to keep an eye on her.The Rubicon coach and club have a duty to take care of their 11 players but I think they've forgotten that in their zeal to brag about their winning teams and 12 scholarship-earning players.They should pay for the harm that Mia suffered,harm that was 13 preventable if they'd only had their priorities straight.Money can never make things right but at 14 least it can help us afford all of the therapy and educational support services that Mia will need in 15 the future.Without that,I just don't know what will become of Mia. 16 17 Of the exhibits in this case,l am familiar with the following: CDC High School Athlete 18 Fact Sheet; ACE Evaluation Form,and ACE Care Plan for Mia Perez; and the Rubicon Soccer 19 Club Medical Consent/Waiver of Liability and Release. 20 21 I hereby attest to having read the above statement and swear or affirm it to be my own. I 22 also swear or affirm to the truthfulness of its content. Before giving this statement,I was told it 23 should contain all relevant testimony,and I followed those instructions. I also understand that I 24 can and must update this affidavit if anything new occurs to me until the moment before I testify 25 in this case. 26 Casey Perez 27 Casey Perez 28 29 Subscribed and sworn before me on this day,the 23rd of August,2013 30 l3eEk Eckkar& 31 Beth Eckhardt, Notary Public 32 15 CLASSROOM LAW PR.O./EC:1' Oregon High School Mock Trial Competition www.classroomlaw.org 1 Affidavit of Bevin Register,Ph.D.,A.T. 2 3 My name is Dr. Sevin Register; I am 45 years old and the Director of the Sports 4 Medicine Concussion Research Center.The Center is part of the Department of Exercise and 5 Sport Science at the University of Rowe,where I am also department chair and Mihalik-Marshall 6 Distinguished Professor. For nearly twenty years my research has focused on the diagnosis and 7 long-term neurological impact of sport-related concussions. More recently,our center has also 8 begun focusing on injury awareness and prevention among youth athletes. As part of our work at 9 the Center,we offer pre-concussion baseline and post-injury follow-up testing to youth athletes. I 10 saw Mia Perez in February of 2013 after her concussion in December of 2012. 11 12 I became interested in studying concussions about 20 years ago when I worked as an 13 athletic trainer for an NFL pro football team. It seemed as though we did not have a good process 14 to determine when players with concussions could safely return to play. So I earned my Master's 15 degree and my Ph.D. in sports medicine,focusing on balance testing as an objective measure to 16 confirm concussions and recovery from concussions.We can never make athletes 100% safe, 17 though; all sports carry some degree of risk. We can only do our best to reduce the risks as much 18 as possible,realizing that some percentage of athletes will continue to get hurt. 19 20 I suffered a concussion as a high school soccer player myself and,as an adult,I have had 21 two more concussions,one from a skiing accident and another from riding a roller coaster. I 22 know from personal experience that the first concussion puts you at increased risk for more and 23 how it takes less force to cause subsequent concussions. Because of all I've seen,you might say 24 I'm on a personal crusade to raise awareness about the devastating impact of multiple 25 concussions. 26 27 A concussion is a type of mild traumatic brain injury,or mTBI,caused by a blow or jolt 28 to the head. Contrary to what many people believe,only 5 - 10% of concussions involve a loss of 29 consciousness.The injury occurs from acceleration and deceleration forces shaking the brain 30 inside the skull. We've recently discovered that this movement sets off a cascade of 31 neurophysiologic changes which are more akin to "software" problems than "hardware" 32 problems such as cell death or structural changes. We see alterations in the metabolism of 33 glucose (the major fuel for the brain),temporary disruptions in neural membranes that cause 34 impaired connectivity or changes in neurotransmitters,and reduced blood flow in the brain.As 35 the brain attempts to return to normal,any additional physical or cognitive activity can cause 36 symptoms to worsen and even lead to long-term problems. 16 CLASSROOM Lnw PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 In the last ten to fifteen years we've begun to realize how serious the long-term effects of 2 repeated concussions can be. Coaches used to encourage players to "tough it out" and get back in 3 the game; continuing to play after getting your"bell rung" was almost a badge of honor.And we 4 used to think that the brains of children and youth were more resilient than adults so we were less 5 concerned when a youth suffered a concussion. Now we realize that youthful brains are actually 6 more vulnerable and it can take youth athletes longer to recover than adults. 7 8 Every year, U.S. emergency departments treat more than 120,000 youth aged 10-19 for 9 sports and recreation-related TBIs.The numbers are highest in boys football and girls' soccer. 10 Because more boys participate in contact sports than do girls,the overall numbers are higher 11 among boys; but when you compare them across similar sports (basketball, soccer,or 12 baseball/softball), girls are twice as likely as boys to suffer from concussions. And some research 13 indicates that females may face more brain swelling and take longer to recover from concussions 14 than males do. 15 16 Immediately after a blow to the head that causes a concussion,certain signs may be 17 observed.The athlete may appear dazed or stunned; he or she may appear confused about events 18 or slow to respond to questions. He or she might seem clumsy or lose consciousness briefly.The 19 athlete might also exhibit mood swings or personality changes. It is important for coaches to be 20 alert to these symptoms,because the player might try to stay in the game and shake it off,or beg 21 to be put back in if the coach takes him or her out. Sometimes players deliberately try to hide the 22 injury from their coaches; other times the player just is not aware of what is happening because 23 he or she is not thinking clearly. We can educate athletes about the symptoms of a concussion 24 but,especially when dealing with youth players,I feel strongly that the real responsibility lies 25 with the adults in the situation: the coaches,athletic trainers,and parents. It is crucial that regular 26 training be provided to all athletic trainers and coaches working with youth in contact sports to 27 make sure that they are aware of the symptoms and proper treatment of concussions. 28 29 Generally,concussion symptoms fall into four categories.The first category involves 30 difficulty in cognitive activities. Concussed individuals may have trouble thinking clearly, 31 concentrating,or remembering new information; they may feel mentally sluggish,hazy,or 32 foggy.The second category is physical effects: nausea or vomiting (early on),headaches, blurry 33 or double vision,dizziness or balance problems,and sensitivity to light or noise.Affected 34 individuals will say that they have no energy or just"don't feel right."Third,concussed 35 individuals can experience changes in mood or emotion: they may be irritable, sad,nervous,or 17 CLASSROOM LAW PRc11Ec:r Oregon iEgli School Mock Trial Competition www.classroomlaw.org 1 more emotional than usual.And lastly,affected individuals can have changes in their sleep 2 patterns: either difficulty in falling asleep,or sleeping more or less than usual. 3 4 Dr.R.Dawn Comstock at the Center for Injury and Research Policy in Ohio has been 5 collecting data on the reported incidence and symptoms of concussions for high school athletes 6 across the U.S. since the 2005-06 season. Dr. Comstock obtains weekly injury and participation 7 data from.Certified Athletic Trainers (ATs) at a representative nationwide sample of high 8 schools via the High School RIOTM (Reporting Information Online) study. By analyzing the data 9 and tracking trends over time,Dr. Comstock's research helps the National Federation of State 10 High School Associations (NFHS) to develop policies to improve athletes' safety. Data from 11 2005-06 through 2010-1 1 revealed that during a six-year period,an estimated 120,000 12 concussions were sustained by high school boys' soccer players nationwide and 170,000 13 concussions by high school girls' soccer players.The girls' concussion numbers were higher 14 even though the NFHS reports that 10% more boys than girls play high school soccer each year. 15 And these numbers undoubtedly underestimate the true incidence,as they only reflect the 16 concussions that were known to the athletic trainers. 17 18 Dr. Comstock found that while headaches are the most commonly reported symptom 19 among all athletes—approximately 90% report headaches—boys and girls differ in their 20 exhibition of other symptoms. For instance, more boys than girls experience amnesia(27% 21 versus 14%),loss of consciousness (5% versus 2%),and tinnitus (11% versus 5%). In contrast, 22 girls more often report difficulty in concentrating (55% versus 41%),sensitivity to noise (19% 23 versus 12%),nausea(33% versus 24%),and feelings of drowsiness (34% versus 18%). It is 24 important to be aware of these differences so we don't overlook girls who have sustained a 25 concussion. While many people are aware that amnesia or loss of consciousness are symptoms of 26 concussions,complaints of drowsiness or sensitivity to noise may be attributed to busy teen 27 lifestyles rather than recognized as indications of a possible concussion. 28 29 When an athlete is suspected of having sustained a concussion,it is very important that 30 he or she be removed from play right away and not be allowed to go back in the game that day. 31 The athlete needs to be evaluated by a health care professional who is knowledgeable about 32 assessing and treating concussions. Diagnosis still largely depends upon observed symptoms and 33 the patient's report,as CT scans and MRIs appear normal unless the injury is severe enough for 34 intracranial bleeding. 35 18 CLASSROOM LAW PRO}C1' Oregon High School Mock Trial Competition www.classroomlaw.org Physicians frequently use an "Acute Concussion Evaluation," or ACE,questionnaire 2 when interviewing a person thought to have sustained a concussion.The ACE notes the 3 characteristics of the injury,patient symptoms,and risk factors such as previous concussions or a 4 history of headaches that may indicate a full recovery could take longer than normal. After 5 evaluating the patient,the physician should give the individual an ACE Care Plan sheet detailing 6 what the patient should and should not do,and what types of follow-up are recommended. Mia 7 was evaluated using an ACE the day after she sustained a concussion while playing on her 8 school soccer team. It would have been important for Mia to tell her future coaches about that 9 concussion; I do not know whether her coaches were informed or not. 10 11 After sustaining her first concussion last spring, Mia was at greater risk for a subsequent 12 concussion even with a lesser application of force.A study conducted by McGill University in 13 Montreal found that college soccer players who sustained one concussion were 4 to 6 times more 14 likely than uninjured players to sustain a second concussion. It is critically important for 15 organizations involved in youth athletics, whether schools or clubs,to ask incoming players 16 about any past incidents of concussions so they will know to monitor affected players more 17 closely. Any failure to specifically ask for such information is unthinkable; no responsible 18 organization could possibly fail to recognize the importance of such information. 19 20 Most players who have sustained a mild concussion are symptom-free within a week to 21 ten days, but it takes others much longer to recover. According to the RIOTM data,concussion 22 symptoms resolved within 6 days for 83% of high school boys' soccer players and 75% of high 23 school girls' soccer players,leaving a substantial percentage with symptoms lasting a week or 24 longer. Since adolescent brains are still developing,it is better to err on the side of caution when. 25 evaluating return-to-play: "When in doubt,sit them out." Individuals vary greatly in the time 26 needed for a full recovery,and sometimes after physical symptoms have resolved,the player 27 may have lingering cognitive impairment or brain metabolism abnormalities. 28 29 Rest is a key part of recovery,and this includes rest from learning and mental stimulation 30 as well as physical rest. Youth athletes often feel stressed by the need to take time to recover, 31 feeling that they should "work through" their symptoms so they do not fall behind in their 32 schoolwork or lose athletic fitness. It is very important for coaches, parents,athletes and school 33 personnel to support the athlete's need to take sufficient time to recover. Research shows that it 34 is even more critical to allow sufficient time when an athlete has suffered a repeat concussion. 35 For instance,after a second concussion,a player should sit out for a minimum of 2 weeks even if 36 the symptoms all clear up within 30 minutes of the incident. 19 CLASSROOM LAW PRoJrc I" Oregon High School Mock Trial Competition www.classi-oomlaw.org 1 An athlete should be completely free of symptoms at rest and have no symptoms with 2 cognitive stress (such as reading or schoolwork) before starting on a gradual progression to 3 return to play. If symptoms return at any point,the athlete must stop and rest; when they are 4 symptom-free,they must return to the previous stage that they completed without symptoms. It is 5 important that the athlete not progress too quickly and that he or she pay careful attention to any 6 recurring symptoms and honestly report those to their parent,coach,or athletic trainer. While a 7 coach or athletic trainer can observe symptoms such as poor balance,the athlete must be willing 8 to report other symptoms like difficulty concentrating which the coach cannot see as readily. 9 10 In my evaluation of Mia Perez at the Center in February, I conducted a number of 11 assessments,including computerized cognitive testing,computerized balance testing,clinical 12 cognitive and balance testing, symptom assessment,and an assessment of her history of 13 concussion.All of her test results showed that she was suffering from post-concussive syndrome. 14 During my evaluation she displayed difficulties with visual and recall memory, slowed 15 information processing,and inattentiveness. She was experiencing ongoing and severe 16 headaches,including migraines; other physical symptoms included poor balance, sensitivity to 17 light and noise,and unusual sleepiness. Mia also reported mood swings,intolerance to stress,and 18 feelings of depression. All of these symptoms made it impossible for her to attend school or take 19 classes online. I evaluated her again in early August,and although her symptoms were 20 marginally improved, she was still unable to tolerate more than one online class for school. Her 21 low tolerance for stress,continuing headaches,and sensitivity to light and noise will certainly 22 decrease the likelihood of her ability to be present in the courtroom. 23 24 From my assessments and interviews with Mia and Casey Perez,it appears that Mia may 25 have suffered one concussive event on Monday,November 26,and very likely suffered two 26 concussive events on December 2,2012.The die was cast when Coach Dempsey left Mia in the 27 game after the first event on December 2,for the occurrence of a second blow in the same game 28 is almost certainly a key factor in her ongoing and debilitating problems. We know that in the 29 recovery phase,rest and avoidance of a second head injury is imperative; when 'cerebral] blood 30 flow is low las occurs after a concussion,another injury could be catastrophic. If the coach had 31 recognized Mia's symptoms and removed her from the game after the first incident, Mia almost 32 certainly would have received more appropriate and timely care,greatly increasing her chances 33 for a full recovery. Given the seriousness of her condition more than a year after her injury,it is 34 strongly likely that Mia will continue to suffer significant physical and cognitive problems for 35 the rest of her life. It is heartbreaking to know that a young woman with a bright future ahead of 36 her has almost certainly had that future snatched away,all because a soccer club and soccer 20 CLASSROOM LAW PRO)I,L i Oregon I Iigh School Mock Trial Competition www.classroomlaw.org 1 coach were too blind to see what was right in front of their faces. We have to do whatever it 2 takes to put a stop to this type of tragedy. Max's and Jenna's laws passed by the Oregon 3 legislature in 2009 and 2013, respectively,are a good start. 4 5 Of the exhibits in this case, I am familiar with the following: ACE Evaluation Form and 6 Care Plan for Mia Perez; CDC Fact Sheet: "Facts About Concussion and Brain Injury"; Sports 7 Concussion Fact Sheet SB 721: Jenna's Law; and my own Curriculum Vitae. 8 9 I hereby attest to having read the above statement and swear or affirm it to be my own. I 10 also swear or affirm to the truthfulness of its content.Before giving this statement,I was told it 11 should contain all relevant testimony,and I followed those instructions. I also understand that I 12 can and must update this affidavit if anything new occurs to me until the moment before I testify 13 in this case. 14 15 gh Zrillsx 16 Bevin Register,PhD,AT 17 18 Subscribed and sworn before me on this day,the 233rd of August,2013 19 I eEk EckhordE 20 Beth Eckhardt, Notary Public 21 21 CLASSROOM LAW PROD] c1' Oregon High School Mock Trial Competition www.classroomlaw.org Affidavit of Tobin O'Reilly 2 3 My name is Tobin O'Reilly. .1 am 35 years old. I teach Sports Medicine, Health,and PE 4 at Rowe High School in Rowe,Oregon. l also coach the boys' and girls' varsity and JV soccer 5 teams. I've always wanted to coach and teach at the high school level because I love seeing 6 students' excitement when they learn a concept or skill for the first time. And RHS is a great 7 place to work! As the only high school in town,we have fantastic community support for all of 8 our programs. When we play our arch-rivals from Carthage High School in soccer on a Friday 9 night,the bleachers are packed with students and townspeople cheering on our team! 10 11 I've always loved soccer; I played in high school myself and became a FIFA-certified 12 soccer referee to help pay for college. I even earned a scholarship to play soccer at the University 13 of North Carolina where I majored in Exercise and Sports Science with a minor in Coaching 14 Education. Before I graduating,I began coaching youth soccer part-time at Triad Soccer Club 15 and started attending soccer coaching courses. I eventually earned my NSCAA (National Soccer 16 Coaches Association of America) Advanced National Coaching Diploma,their second highest 17 certification. It is an intense course,equivalent to a USSF"B" level license. 18 19 After I earned my Advanced National Diploma,I heard that Rubicon Soccer Club was 20 looking to hire a club Director. Rubicon was still very new at that time,and the position sounded 21 like a great opportunity,maybe the only thing that could have lured me away from teaching at 22 RHS. I applied for the position and thought my interview went well but Rubicon hired Jordan. 23 Reddick. I couldn't believe it. Sure,Jordan had played pro ball and I hadn't, but other coaches at 24 Triad Soccer Club said that Jordan was too focused on winning without regard to player safety. 25 In fact,they were relieved when Jordan left. I had to agree; I had seen Jordan's angry behavior 26 on the sidelines when his/her team wasn't playing well. On more than one occasion,I saw Jordan 27 kick chairs or trashcans when his/her team was losing,and Jordan often yelled insults at players 28 who made mistakes. I hate to admit it, but I kind of lost my head and posted some nasty 29 comments about Jordan on the online soccer coaches' forum. It wasn't the wisest idea,but I felt 30 pretty strongly that Jordan got the job that should have been mine. 31 32 I learned a lot about general sport safety and fitness in my college classes and coaching 33 certification courses. I know that sports injuries can hurt the whole team so I do everything I can 34 to keep our players healthy. I make sure they are hydrated and eat the right kinds of foods before 35 and after games and practices. I talk with them about getting enough rest and,of course,about 22 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroornlaw.org 1 keeping their schoolwork as their top priority. A few of them will be able to play ball in college 2 but most of them won't, so I emphasize that they need to have good grades to stay on the team. 3 4 When I first started coaching, we didn't learn much about concussions in my training 5 classes. We mostly learned about sprains, strains,hydration and that sort of thing.But several 6 years ago I heard in the news about several high school football players who died after suffering 7 a second concussion in a game or practice. I knew soccer players sometimes got repeat 8 concussions --I had a teammate in college who had short-term memory problems and recurring 9 headaches after several concussions—so I started reading all I could about concussions. We 10 didn't have enough money to hire athletic trainers at RHS —that made it my job to stay on top of 11 current research in the field. 12 13 In 2010,I learned about the"Heads Up"concussion awareness initiative of the Centers 14 for Disease Control and Prevention and Oregon's Max's Law.The CDC provides a free online 15 training video for coaches,as well as fact sheets for student-athletes and parents.The 16 information is incredibly helpful; it tells the signs and symptoms of concussions,how to prevent 17 them and what to do if you suspect an athlete has a concussion.The website has a guidebook for 18 high school coaches,and clipboard stickers and wallet cards that make it easy to keep the 19 information with you.That fall I began implementing the CDC recommendations at the 20 beginning of the season. I sent home the CDC high school athlete and parent fact sheets with all 21 my students because I wanted to make sure that my players knew not to hide their symptoms or 22 try to"play through" the pain. I put up several CDC posters in my office and in the gym to 23 remind students to take concussions seriously. As those posters say,"When in doubt,get 24 checked out; it's better to miss one game than the whole season." Soccer is a great game,but it is 25 just a game. I would never risk a player's health for a win. 26 27 Our boys' soccer team advanced far into the playoffs in the fall of 2011 and,when the 28 girls' season began in the spring of 2012,I knew they had the potential to make the playoffs,too. 29 Mia Perez,a"striker" and our leading scorer,already had a year of experience on the varsity 30 team since she made the team as a freshman. I had never had a player like Mia. She was fast,had 31 wonderful ball control,could place her shot exactly where she wanted it,and had an intuitive feel 32 for the game. She had an incredible work ethic and her example inspired the other players. She 33 was well-liked and respected by all of her teammates,even the seniors,and they voted her as a 34 co-captain at the beginning of the spring. I knew that if any of my players had the potential to 35 play in college or the pros, it was Mia. 23 CLASSROOM LAW PROILCr Oregon 111gh School Mock Trial Competition www.classroomlaw.org 1 The team,and Mia in particular,certainly lived up to my expectations. We were 2 undefeated going into the playoffs,and our first playoff game was against our archrival, 3 Carthage High School. We hadn't played them in the regular season; the game was rained out 4 and we were never able to reschedule it. So I think the whole town was in the bleachers when we 5 faced Carthage at home in May. We really dominated in the first half; Mia scored a goal and sent 6 a beautiful cross in to get an assist on another goal.I'd never seen the girls play better. With a 2- 7 0 lead at halftime,we were focused and confident going into the second half. 8 9 But about 20 minutes into the half,Mia collided with a Carthage player when trying to 10 score on a header. Mia went down and seemed to hit her head on the ground. She took a minute 11 to get up and looked kind of dazed, so I pulled her out right away. I asked Mia some questions 12 based on my CDC clipboard sticker. She answered my questions slowly and she said she was 13 feeling"foggy." It was clear to me that she might have sustained a concussion so I told her she 14 would need to sit out for the rest of the game.Ten minutes later Carthage scored and Mia begged 15 to go back in,but there was no way I was going to do that. I'd rather lose the game than risk my 16 player's health. 17 18 Carthage came close to scoring but our defenders were great,and we won 2-1.The crowd 19 and all the players went wild,except for Mia. She had a huge grin on her face but she didn't try 20 to dance around like the other girls. After things calmed down,I spoke with Mia and her parent 21 and told them she needed to go to a doctor the next day because I suspected she might have a 22 concussion.They both assured me they would do that first thing. When she left that night,Mia 23 said "Don't worry,Coach,I'll be ready to play the next game." I didn't say anything but I knew 24 that was unlikely. 25 26 Max's Law became law in Oregon in 2009 and it requires schools to follow a particular 27 procedure before allowing athletes to return to play after a concussion.The law meant that Mia 28 wouldn't be allowed to return to play until she had medical clearance.That was okay with me 29 because my players' health and well-being comes first.The law didn't apply to clubs like 30 Rubicon but that changed this summer when the legislature passed Jenna's Law. It was named 31 for a gold medal skier from Sisters who had at least ten concussions before hanging up her skis 32 and so,now,clubs have to follow procedures to protect players,too. A Fact Sheet about sports 33 concussions,Max's Law,Jenna's Law and so on are easy to find on the internet. I also got a cell 34 phone app that helps coaches determine right on the sidelines whether a player may have 35 suffered a concussion—well worth the $4 cost,in my opinion. At RHS we developed emergency 36 plans and give instruction sheets to our students and parents in compliance with the law. 24 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 Anyway,Mia did see a doctor the next day and I learned that he said she needed to rest 2 for a week and then return to see him.Without Mia in the game on Saturday,we lost a close 3 match to the Gallic High School team. Of course Mia and her teammates were disappointed,but 4 I told them we would be even better the next year,and the important thing was that everyone 5 played their best. 6 7 As.a junior that year,Mia didn't have to take PE as a required course.Yet she signed up 8 for my Tuesday-Thursday "Advanced Personal Fitness" class where students increase their 9 fitness through high-intensity aerobics,circuit training,Tae-Bo,Zumba and weight training. Mia 10 seemed to enjoy the class and said it gave her a nice break from all of her AP and Honors 1 i courses. She always went all-out in class and often encouraged other students who were not as 12 athletic as she was.That's why I remember thinking that she must be getting sick the week after 13 Thanksgiving when she asked to sit out halfway through our Zumba session on Tuesday. When.I 14 asked if she was okay, she said she had a bit of a headache from all of her studying for tests that 15 week. On Thursday she didn't seem any better so I gave her a pass to go to the library to study 16 instead of sitting around in the gym. She had talked about having a big club soccer tournament 17 that weekend,so I hoped she would recover in time to play. 18 19 The next Monday I heard that Mia had sustained a serious concussion at the soccer 20 tournament. She has not come back to classes on campus at all since that weekend because of her 21 lasting injuries. I am devastated to hear that Mia, such a promising athlete and student,has 22 suffered such serious long-term problems because of that concussion. I don't know the specifics 23 of her injury but I do know that if a coach doesn't recognize the symptoms of a concussion and 24 keeps a player in the game who has taken a hard hit, it can lead to problems like this.And, 25 unfortunately,Max's Law only applies to public schools not to club soccer organizations,and 26 Jenna's Law just passed this summer so it didn't apply. Even so,all coaches are still responsible 27 for the safety of their players.The dangerous effects of concussions had been in the news long 28 before Mia was injured in December,and the CI)C materials have been available online for 29 several years.Any reasonable coach or club who cares about their players would have taken 30 steps to educate themselves and their team families about concussions even without being 31 required to do so by law. I did it before Max's Law because it's just the right thing to do. 32 Tragically, it takes a lawsuit to make some people realize that concussions are no joke,so they 33 need to take their responsibilities seriously. 34 25 CLASSROOM LAW PROJt C1 Oregon High School Mock Trial Competition www.classroomlaw.org 1 Of the exhibits in this case,I am familiar with the following: CDC High School Athlete 2 Fact Sheet; CDC High School Coaches' "Heads Up"Clipboard Sticker; CDC High School 3 Athletes' Signs and Symptoms Poster; and Sports Concussion Fact Sheet SB721: Jenna's Law. 4 5 I hereby attest to having react the above statement and swear or affirm it to be my own. 1 6 also swear or affirm to the truthfulness of its content.Before giving this statement,I was told it 7 should contain all relevant testimony,and 1 followed those instructions. I also understand that I 8 can and must update this affidavit if anything new occurs to me until the moment before I testify 9 in this case. 10 11 Tobin O'Reilly 12 Tobin O'Reilly 13 14 Subscribed and sworn before me on this day,the 23'of August,2013. 15 13eEk eckkardE 16 Beth Eckhardt,Notary Public 17 26 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 Affidavit of Shannon Dempsey 2 3 My name is Shannon Dempsey. I am 27 years old. In 2009 I began coaching soccer full- 4 time for the Rubicon Soccer Club after graduating from Julian College in Rowe,Oregon, with a 5 degree in communications. I played soccer at Julian on a full scholarship,and I was the second. 6 leading scorer on my team in my senior year even though I played midfield. I also coached part- 7 time at Rubicon during my last two years in college. When I graduated,I got an offer to play in. 8 the pros but I turned it down because the money for pro players in the US isn't all that great 9 unless you're a superstar. Rubicon Soccer Club Director Jordan Reddick told me I could coach 10 three teams and go full-time if 1 wanted,and I could use my communications training to help 11 market the club and update the website. It sounded good to me,so I did. I've been really happy 12 with the decision to work for Rubicon. It is the best club in the state and a lot of our players have 13 gone on to play in college. 14 15 Right now I'm coaching the Under-14 boys' premier team,the U-15 second division 16 classic boys' team,and the U-16 first division boys' team. Club soccer is divided into different 17 competitive levels,with premier level soccer being the highest statewide division,followed by 18 first division classic teams,second division classic teams,and challenge level teams. Below the 19 challenge level teams are recreation level teams which usually have volunteer coaches and 20 players who are just playing for fun.Although I've coached both genders,I enjoy coaching the 21 boys' teams more than the girls' because the guys are more focused on the competition and there 22 is less social drama. I have a harder time telling what the girls are thinking but the guys just blurt 23 it all out. 24 25 Before I could start working for Rubicon full-time,I had to obtain my National "D" level 26 soccer coaching license from the U.S. Soccer Federation. USSF is the only organization allowed 27 by the international soccer federation ("FIFA") to issue coaching licenses in the U.S.The 28 licensing course was pretty intense. It lasted six days and included classroom instruction, 29 homework and sessions where we had to plan and lead practices.The course covered learning 30 styles of players, soccer techniques and soccer tactics.We also had a short session on the care 31 and prevention of injuries which mostly focused on strains and sprains, broken bones and heat 32 exhaustion. We barely touched on concussions.To pass the course I had to pass oral,written,and 33 practical field evaluations. I think that out of the 30 people taking the course with me,only 20 of 34 us earned our National "D" license without having to repeat the course. 35 36 After I got my "D" license,the club moved me up from coaching challenge teams to 27 CLASSROOM LAW PROJRC1' Oregon High School Mock Trial Competition www.classroonilaw.org 1 coaching three classic level teams. I was glad for the promotion because it meant I got to coach 2 players who were more talented and motivated. Don't get me wrong,I enjoyed the enthusiasm of 3 the challenge level players but I felt that my skills were put to better use with the more skilled 4 players. I asked to coach mainly boys' teams so that's all that I did for the first few years. 5 6 In early July of 2012,. Michelle Foudy,the coach of the Rubicon U-17 girls' Premier 7 team,found out that her dad had been diagnosed with cancer and wouldn't live past Christmas. 8 She was devastated and left to be with him right away. Rubicon doesn't have assistant coaches 9 for the teams so the club needed someone to step in and take Michelle's place. Most of the other 10 full-time coaches already had four teams so,when Jordan Reddick asked if I was up to the job, I 11 jumped at the chance. It would be my first time coaching girls but I couldn't turn down an 12 opportunity to coach one of the top teams in the club. I've always gotten along great with my 13 players so I figured I could handle it. 14 15 Michelle had evaluated the players at tryouts and picked the maximum of 18 players. 16 They had already turned in all of their paperwork to the club administrator,who had given the 17 team medical forms to the team manager. I didn't ask to look at the forms; I figured I'd get them 18 if a player ever got injured and we needed to know her insurance information.The team hadn't 19 started practicing yet so I called a meeting to get to know everyone,and I brought watermelon to 20 help put everyone at ease.The girls seemed impressed by my background. And although they 21 were certainly concerned for Coach Foudy,they seemed to accept the coaching change without 22 complaining.When we began holding our regular practices on Mondays,Wednesdays,and 23 Thursdays, I was very impressed by their skills and teamwork. I knew that with a bit of luck,we 24 were going to have a great season. And,if the team did well,that would help solidify my 25 reputation in the club,too. So I wanted to make sure I helped the girls to win. 26 27 The club website has links to great information on sports nutrition and hydration so I 28 made sure the girls knew what to eat and drink to help them perform their best at practices and 29 games. Rubicon is also involved in an ACL Injury Prevention study in partnership with Julian 30 College. It's a pretty cool program; it seemed to be working because none of my players ever 31 tore their ACL. 32 33 Coaching girls was different than coaching guys. Girls seemed to need more time to 34 socialize. It took some getting used to and maybe I might have come across as a bit stern at first. 35 I always try to treat my players equally and make sure that I maintain a professional relationship 36 as a coach,not as a"friend." I got the feeling that I was different from Coach Foudy in that 28 CLASSROOM LAW PROJi7.rr ()r-egon High School Mock Trial Competition www.classroomlaw.org 1 respect. Since I saw my primary purpose as making them the best soccer players that they could 2 be, I didn't really take time for a lot of small talk about school or their boyfriends. I figured that I 3 was better off staying out of all of the drama. 4 5 The girls were highly motivated to finish the season undefeated so they could advance 6 from statewide Premier level play to the multi-state Regional Premier division in the next season. 7 At least six of the girls were hoping to earn college scholarships and they knew that advancing to 8 Regional Premier would get them a lot more,exposure to college coaches. So the players worked 9 incredibly hard in practice and really stayed focused.Team co-captain Mia Perez was a big part 10 of that. She had an incredible work ethic and really set a high standard for the rest of the girls to 11 follow. She also organized "team bonding" times outside of practice because she said it would 12 help the team be cohesive on and off the field. I wasn't part of those gatherings,but it did seem 13 to make the team closer. 14 15 All of their hard work paid off and the team won every game in the regular season. 16 Incredibly,all of my players had made it through the season without injury. Mia was amazing 17 playing as a striker. She scored at least one goal in every game,two goals in two games,and a 18 "hat trick" (three goals) in one game! She clearly had the potential to play in college and maybe 19 even in the Olympics or the pros. We went on to win the State Cup championship two weeks 20 before Thanksgiving.I knew that the team's success had caught the eye of Jordan Reddick and I 21 figured I would have my pick of teams for the next year.All we had left now was the December 22 College Showcase tournament,one week after Thanksgiving. 23 24 Mia was especially excited about the College Showcase because she knew a lot of the top 25 college coaches were planning to be there. I think several coaches were attending specifically to 26 see Mia so I wanted to give her as much playing time as I could. College Showcase tournaments 27 are a bit unusual; winning the game isn't the most important thing, being seen is. So players 28 usually don't play quite as roughly as in a typical tournament because they can't play if they get 29 hurt. I figured that since all of my players made it through the season without injury,we were 30 probably home free now. 31 32 We didn't practice the week of Thanksgiving but resumed practice the next Monday. 33 During the scrimmage at the end of practice,Mia was tripped,fell,and hit her head on the 34 ground pretty hard. She was slow to get up and she seemed confused for a moment about where 35 she was. She was also holding on to her head and saying that she felt a little dizzy so I made her 36 sit out the last 10 minutes while I finished leading practice. As soon as practice ended,Mia 29 CT.ASSROOM LAW PROJrCr Oregon High School Mock Trial Competition www.classroomlaw_org I headed to her car before I could talk with her. I meant to call and check on her but it was too late 2 when I got home and it slipped my mind the next day. 3 4 Mia emailed me on Wednesday to say she had had a big test and couldn't make practice. 5 That was unusual; I think it was the first practice she had missed all season. On Thursday we just 6 had a light practice; I mainly spent the time reviewing the scouting reports on our opponents. 7 Mia seemed tired and quieter than usual.When I asked her how her test had gone, she acted 8 confused for a moment and then said it went okay. She said she had a bit of a headache from 9 stress and staying up late studying but she'd be tine by our game the next day. I didn't think 10 much else about it; I could remember pulling all-nighters before important tests and knew it 11 could really wipe you out. I figured she'd rest up that night because I knew how much it meant to 12 her to impress the college coaches. 13 14 On game day everyone,including Mia,was excited to get going. We were playing a team 15 from Triad Soccer Club that was good but not great. I figured we should be able to put lots of 16 goals on the board and that would make Jordan Reddick happy.Jordan always liked it if we 17 could beat his/her old club. Lots of college coaches were at our field,and I heard several of them 18 mention Mia's name specifically. I wanted to give Mia as much playing time as I could so they 19 could get a good look. 20 21 Mia and the other co-captain,Megan Cheney,led the warm-ups and I started them in 22 their usual positions at striker and center midfielder. But about 10 minutes into the game, I 23 noticed that Mia wasn't playing as well as usual so I subbed her out to check on her. She said she 24 was just a little tired still and she begged to go back in so she could show the college coaches 25 what she could do.After she drank some water,I subbed her in and she did play better. She was 26 in a perfect position to score on a header when we got a corner kick near the end of the half,but 27 she sent the ball over the goal. I think she might have gotten jostled by a defender but the referee 28 didn't call a foul. Mia sort of stood around for a minute looking disgusted that she didn't score 29 and Megan went over to encourage her.Then Mia jogged back into position,although not with 30 her usual energy and enthusiasm. I didn't think anything of it at the time. 31 32 The first half ended with the score tied 0-0.The team was playing okay but not up to its 33 potential so I got after them at halftime. Sure, winning isn't the most important thing in a College 34 Showcase but goals are always impressive to college coaches and we should have been beating 35 that team easily. After I finished, Mia told me,"don't worry,coach,I'll get a goal for us," and 36 she ran onto the field. Immediately Megan came over to me and said that she was concerned 30 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org I about Mia and maybe I should pull her out. She said that she knew that Mia wanted to play but 2 that she just didn't seem like herself. Megan also said something about asking Mia if she was 3 okay "after she took an elbow on that header" but she got a blank look and didn't say anything. 4 Before I could reply,the referee blew his whistle to start the second half and Megan had to run 5 onto the field. 6 7 I thought about yelling for a sub to pull Mia out but she had seemed so eager to get back 8 on the field that I decided to just watch her. Five minutes later Mia sent a rocket toward the goal 9 but the goalkeeper made an amazing save. Unlucky! Mia seemed back to her usual self; I knew it 10 was just a matter of time until she would score. Maybe 10 minutes later a teammate sent a 11 beautiful pass to Mia just outside the penalty box and Mia took a touch on the ball to get ready to 12 shoot. From out of nowhere a defender rushed at her and tackled the ball hard,and Mia lost her 13 balance. She didn't even have time to put out her arms to stop her fall,and she hit her head on 14 the ground really hard. The referee was sprinting over blowing his whistle; I figured he would 15 call for a penalty kick and Mia would get her goal after all. But Mia didn't get up,and she wasn't 16 moving.The referee motioned for me to come out on the field and,when I got there,I saw that 17 Mia's eyes were closed and it looked like she was unconscious.The field marshal and athletic 18 trainer ran out,too,and they radioed for the ambulance to come and get Mia. Casey Perez had 19 run out on the field,too,and I said how sorry I was that Mia had gotten hurt and how I was sure 20 she would be okay. 21 22 After the game ended,I called Casey's cell phone to get an update on Mia. It must have 23 been three hours later before I got a call back. Casey said that Mia had a serious concussion and 24 that she was going to stay in the hospital overnight for observation. Casey said Mia had 25 mentioned something about hitting her head in practice on Monday and why didn't I make sure 26 Casey knew about it!?! Casey also told me that Mia had suffered a concussion in the spring on 27 her school team and I should have known to keep a closer eye on her.That was the first thing I 28 had ever heard about a previous concussion! Neither Casey nor Mia had ever mentioned it to me 29 before. 30 31 After Casey told me that, I looked at Mia's Medical Waiver form in the team manager's 32 notebook. I saw that the form mentioned Mia's concussion from the spring. Even though the 33 team manager brought those forms to all of our games as she was required to do,I had never read 34 through them before. I guess I should have read them all but it just didn't occur to me in the 35 busyness of the transition back in the summer. 36 31 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 If I had known about Mia's previous concussion,I would have watched her more closely 2 but I don't know what I could have done differently. I knew she hit her head in practice on that 3 Monday but players hit their heads in practice all the time. She wasn't knocked out or anything 4 so I figured she was okay. I mean,when I was playing soccer in college we just played through 5 the pain; a little dizziness didn't stop me from playing. I've always thought you had to be 6 unconscious to have a concussion. 7 8 I am truly sorry that Mia is still having so many problems. She was always a leader on 9 the team and had so much potential. I would never do anything on purpose to put her in danger. 10 But I can't be expected to read a player's mind,especially if the player tells me that she's just 11 tired from studying,what am I supposed to do?Am I really supposed to pull out every player 12 who complains of a headache or a little dizziness after taking a hit in a game?Soccer is a 13 physical sport; top players have to be tough. 14 15 Of the exhibits in this case,I am familiar with the Rubicon Soccer Club Medical 16 Consent/Waiver of Liability and Release. 17 18 I hereby attest to having read the above statement and swear or affirm it to be my own. I 19 also swear or affirm to the truthfulness of its content.Before giving this statement,I was told it 20 should contain all relevant testimony,and 1 followed those instructions. I also understand that I 21 can and must update this affidavit if anything new occurs to me until the moment before I testify 22 in this case. 23 24 51-iannan 25 Shannon Dempsey 26 27 28 Subscribed and sworn before me on this day,the 27`h of August,2013. 29 IBeEk Eckkwrc&E 30 Beth Eckhardt,Notary Public 31 32 33 34 35 32 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org Affidavit of Jordan Reddick 2 3 My name is Jordan Reddick. I am 39 years old and have been the Director of the Rubicon 4 Soccer Club since 2006. I attended Julian College on a soccer scholarship and started at center 5 back (defender) all four years. I earned my bachelor's degree in Sport Administration in 1995, 6 which included coursework in sport marketing, statistics,finance,licensing,facility and event 7 management,and community relations. After I graduated I played professionally for a few years 8 before coming back home to Oregon in 1998. I put all my knowledge to use by coaching youth 9 soccer part-time at Triad Soccer Club while working as Director of the Parks and Recreation 10 Department in the town. In 2004 I became the fulltime Director of Player Development for the 11 Under-15 through Under-18 year old teams at Triad,but I soon realized that I disagreed with the 12 Triad Board of Directors over their coaching philosophy.The Triad teams were 13 underperforming, in my opinion; they should have been winning State Cup championships with 14 the talented players in the club. When I was offered a position at Rubicon,I was happy to leave 15 Triad. 16 17 Rubicon was the "new kid on the block" back then; the club had only been in existence 18 since 2005 and was still trying to "prove" itself. I knew that Rubicon could gain respect from 19 other clubs by producing players who earned college scholarships,so I set high standards for my 20 coaches. I insisted that all of my classic level coaches must have played in college so they could 21 demonstrate correct soccer techniques and understand how to compete at a high level. I had 22 earned my National "C" level coaching license and I required my coaches to earn a National "D" 23 license or higher(an "A" license is the highest).The certification courses are rigorous,covering 24 how to teach soccer techniques and tactics and including a short session on first aid.I knew that 25 requiring my coaches to obtain their National "D" license would make sure that they not only 26 knew how to play soccer,they would also learn how to coach soccer. 27 28 Under my leadership,Rubicon Soccer Club has excelled. We are now the third largest 29 club in the state,and every year about a dozen of our players earn college soccer scholarships. 30 We have twenty classic boys' and girls' teams in the Under-15 to Under-18 age groups,eight of 31 which are at the highest"Premier" level of play. All of our Premier teams attend at least three 32 tournaments every year in addition to the State Cup championship,and our club office is full of 33 their trophies. Between our recreational,challenge,and classic teams,we have over 2000 34 athletes playing soccer at Rubicon. I think our club success proves that we are on the right track, 35 and the huge turnout of players at tryouts every year shows that the parents think so,too. 36 33 CLASSROOM LAW 1'ROil.,C'I' Oregon High School Mock Trial Competition www.classroonalaw.org 1 In order to get qualified coaches, I have to pay them appropriately so club fees for the 2 classic players are not cheap. For the high school age players (U15 -- U18) who only play club 3 ball in the high school off-season (fall club ball for girls, spring for boys),club fees are $1200 4 per year, plus a$250 registration fee,plus $300 for the uniform,plus the cost of attending 5 tournaments. Altogether it probably costs $3000 per year for players on the top classic teams. 6 Our fees are in line with the other clubs,and we do have some scholarship money available for 7 players who can demonstrate a need. 8 9 Each team has one paid coach and a volunteer manager; we do not have money for paid 10 assistant coaches or athletic trainers. We are not unusual for not having trainers; only the largest 11 soccer club in Oregon has an athletic trainer on staff. However,we do have an association with 12 the sports medicine department at Julian College.The college provides athletic trainers at our 13 club-hosted tournaments,and we refer players who need services to their trainers and physical 14 therapists. It's a great arrangement; the sports medicine students at Julian College get hands-on 15 experience and we get services for free. 16 17 Our players' health and safety are very important to us. We emphasize health and injury 18 prevention in our club because I know from personal experience what a difference good health 19 habits can make.Both in college and in the pros, I had coaches who were fanatics about proper 20 nutrition before and after games and practices. So we have links on our website to lots of 21 information about hydration,pre-game and post-game meals,and how to eat right when traveling 22 to tournaments. We also remind the players that proper rest is important because a tired player is 23 at increased risk of injury. When I checked last summer, I found that fewer than half of the 24 soccer clubs in the state have any kind of nutrition or hydration information posted on their 25 website,much less any additional information on injury prevention. 26 27 To show our dedication to our players' safety,just look at our ACL Injury Prevention 28 Project in partnership with Julian College.We're the only soccer club in the state that is involved 29 in this type of research project.The ACL,or anterior cruciate ligament, is one of the main 30 ligaments that stabilize a player's knee. It can get torn if the player tries to turn while her foot is 31 firmly planted,or if a player lands wrong after jumping,or sometimes during a collision with 32 another player. Female players are especially at risk for ACL tears. And it's a big deal; a player 33 who tears her ACL is likely to need surgical repair and then 6 to 9 months of rehab before she 34 can play again. So sports medicine grad students at Julian College work with players on our 35 classic teams to help them learn how to move and jump correctly to prevent ACL injuries.The 36 program seems to be working. Our players show improvement at the end of the season,and they 34 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 have lower rates of ACL injuries than many other clubs in the state. So it's crazy to say that our 2 club isn't concerned about injury prevention and player safety. 3 4 It's true that we don't have any information or links on our website about concussions 5 although we are planning to add that before next season. I had always thought that serious 6 injuries from concussions happened to football players or boxers. I think there might have been 7 some articles about concussions in my coaching magazines a few years ago,but I didn't read 8 them very closely because I was setting up our ACL Injury Prevention Study at the time. When I 9 was playing soccer,the big concern for soccer players was always torn ACLs or broken bones. 10 Sure,I suffered one concussion when I played professionally and several of my teammates had 11 concussions. But we all stayed in the game or went back in the very next game and none of us 12 had any problems. According to the US Youth Soccer Association (USYS),over 3 million youth 13 soccer players are registered to play across the United States so, if concussions were such a big 14 problem,you'd expect to hear about it all the time. 15 16 The USYS isn't the only resource for soccer information. Every soccer club in Oregon is 17 a member of the Oregon Youth Soccer Association (OYSA). OYSA is a member of both the 18 USYS and the US Soccer Federation (USSF),both of which are under the oversight of FIFA,the 19 international governing body for soccer.The OYSA,USSF,and USYS are all non-profit 20 organizations designed to provide education and support for soccer players,coaches,and clubs. 21 They run the certification classes for coaches both statewide and nationally,and they help 22 organize and run statewide, regional,and national tournaments.They want to make sure that the 23 sport stays safe and fun for everyone. So these organizations post educational information about 24 health and injury prevention on their websites. 25 26 I was not aware of any information about concussions on the USYS or USSF sites when 27 Mia was injured. If it was on there,it wasn't immediately obvious.After Mia was injured,I did a 28 specific search on the USYS site and found concussion protocol and notification forms that were 29 posted in August,evidently for use in USYS Regional and National tournaments. But I did not 30 know about them at that time. I do know that the USSF started posting medical information on a 31. variety of topics on their site last March. Obviously,that was too late to help Mia Perez,and you 32 still have to search for it to find it. I was not familiar with Jenna's Law at all until this trial. 33 34 I have heard of the CDC but I thought they mainly tried to track down the causes of 35 disease epidemics like the flu. I do remember seeing some free"Heads Up" concussion kits for 36 coaches at a Triad Soccer Club tournament back in November. I couldn't pick one up because 35 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www_classroonilaw.org 1 my hands were full at the time and I forgot to go back later to get one. I don't think any of our 2 coaches got them either; at least no one told me about getting one. 3 4 I was at the College Showcase tournament in December when Mia was injured; my own 5 U-18 classic Premier boys' team had just finished playing right before Shannon Dempsey's team 6 took the field. I always coach at least two teams every year just to keep my skills sharp,and all 7 of my coaching directors are required to do the same. Anyway,I had gone to the snack bar area 8 to grab a quick bite to eat and then had returned to the field at the start of the second half to 9 watch Shannon's team in action. I knew they were playing a team from Triad that they should be 10 able to beat easily and I was looking forward to watching the slaughter. It's especially satisfying 11 whenever a Rubicon team beats a Triad team. 12 13 I also knew Shannon had several players who were good enough to play in college 14 including Mia Perez. I figured Mia might be able to score a hat trick against this Triad team. Lots 15 of college coaches were on the sidelines as I arrived so I asked the score and was told it was 0-0 16 at the half. I heard a couple of coaches saying that they weren't impressed by Mia Perez; she 17 hadn't been working very hard at all in the first half. I was surprised to hear that because Mia 18 was probably Shannon's best player. 19 20 Mia looked a bit uncoordinated to start the second half,and she wasn't playing with her 21 usual intensity. But then she took a great shot a few minutes later, which was barely saved by the 22 opposing keeper. I figured she'd soon show those college coaches what she could do. Coach 23 Dempsey's halftime talk must have been inspiring because several of Mia's teammates were 24 playing better than I'd ever seen them play before. I was glad to hear the coaches say that maybe 25 it had been worth the trip to come watch the team after all.Keeping those college coaches happy 26 is good for them and good for Rubicon,too. 27 28 But Mia still wasn't running with her usual speed and she looked a bit confused at times, 29 like she wasn't sure where to go or what to do.I started wondering if she was sick or something. 30 Then one of her teammates sent her a great pass about 20 yards out from the goal and Mia started 31 dribbling the ball into the penalty area.The only person between Mia and the goal was the 32 keeper and, with Mia,that was practically a guaranteed goal.Then a defender came out of 33 nowhere from the side and tackled the ball hard and Mia went flying. She crashed to the ground, 34 landing hard on her head.The referee sprinted in,blasting on his whistle and I waited for Mia to 35 get up and score the penalty kick. But she didn't move and, next thing I knew,Shannon,the 36 Julian College athletic trainer,and the field marshal were all on the field huddled around Mia. I 36 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classrootnlaw.org 1 was shocked and must admit I stood there frozen,not sure if I should join them or keep out of the 2 way. I don't have any medical training and figured I couldn't really help so I stayed on the 3 sidelines.The ambulance at the soccer complex soon arrived and took Mia to the hospital. I 4 called Shannon that night to see if s/he had heard anything and was told that Mia had suffered a 5 serious concussion. 6 7 I'm very sorry that Mia was injured that day,and even more sorry that she continues to 8 have problems so long afterward. Mia is a terrific young woman and,of course, I would never 9 want her or any other player to be hurt badly from playing soccer. What happened to Mia seems 10 like a freak accident to me. After all this happened,I checked out the statistics on high school 1.1 sport-related concussions from Dr. Dawn Comstock at Ohio State like I was trained to do in 12 college. Dr. Comstock gathers data on the"rate of concussions per 10,000 athlete-exposures." 13 She found that for every 10,000 high school girls competing in soccer matches on any given day 14 in the US during the 2006 through 2010 seasons,at least 8 sustained a concussion and the vast 15 majority don't involve a loss of consciousness. It's clear that serious concussions like Mia's are 16 certainly not a common occurrence although I guess when you consider how many high school 17 girls play soccer across the country, it can add up. 18 19 Looking back at all that has happened,I just don't know what Shannon or I could have 20 done to prevent Mia's injury. Rubicon was not educating our coaches about concussions at that 21 time but,as far as I know,Triad Soccer Club was the only club in Oregon handing out those 22 "Heads Up" kits to coaches. Of course,coaches from all over Oregon and even other states were 23 at that tournament. Looking back at it now,I wish I had gotten one of those kits. Evidently the 24 CDC had its "Heads Up" materials on its website but the USYS and USSF didn't make an effort 25 to publicize it to all the state associations at that time as far as I know. Maybe I should have 26 known more about concussions then --or maybe hindsight is just 20/20. 27 28 And sure,Max's Law was passed in 2009 so stories on concussions were probably in the 29 news at that time. But I didn't see them and the law did not apply to clubs anyway. And Jenna's 30 Law was not passed until after Mia's injury. We're definitely going to start doing more now at 31 Rubicon to educate our coaches and club families about concussions. I certainly hope that Mia 32 continues to get better and has a full recovery. I understand that Mia and Casey Perez are upset 33 about what happened but I don't think it's reasonable to sue us for Mia's injuries when we have 34 always tried to educate our players about health,good nutrition,and injury prevention. If we only 35 cared about winning,would we have gone to all of that trouble? 37 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org 1 Of the exhibits in this case,I am familiar with the following: Rubicon. Soccer Club 2 Medical Consent/Waiver of Liability and Release; USYS Concussion Procedure and Protocol; 3 USYS Possible Concussion Notification. 4 5 1 hereby attest to having read the above statement and swear or affirm it to be my own. I 6 also swear or affirm to the truthfulness of its content. Before giving this statement,I was told it 7 should contain all relevant testimony,and I followed those instructions. I also understand that I 8 can and must update this affidavit if anything new occurs to me until the moment before I testify 9 in this case. 10 11 Jordan Reddick 12 Jordan Reddick 13 14 Subscribed and sworn before me on this day, the 27th of August,2013. 15 teat eckkardE 16 Beth Eckhardt,Notary Public 17 38 CLASSROOM LAW PROj cr Oregon High School Mock Trial Competition www.classroomlaw.org 1 Affidavit of Chris Durant 2 3 My name is Chris Durant. I'm a senior at Rowe High School and a classmate of Mia 4 Perez's. At least we used to be classmates until Mia was injured and couldn't come to class 5 anymore. We've been friends since middle school when we both ran track.Mia used to say that 6 track made her run fast and that helped with soccer. She was always crazy about soccer,talking 7 about her heroes Cindy Parlow and Mia Hamm,and saying how she wanted to play in the 8 Olympics and pros like them. I've always been into basketball myself; I think soccer is boring 9 because everyone runs around but hardly ever scores. It's true that Mia was the top scorer on the 10 high school varsity team but winning 3-1 or 2-0 isn't exactly exciting,at least not to me. Still,I'd 11 listen to Mia go on about soccer,and she'd listen to me about basketball. She's a good friend that 12 way,always listening to the other person and caring about what they care about.That's one 13 reason why everyone at Rowe loves Mia. She doesn't care if you were a jock or a geek or a 14 slacker, she could find a way to be your friend. So it's hard for me to testify for the defense. But 15 I promised to tell the truth when I was called to testify,and that's what I'm gonna do. 16 17 When we moved from middle school to the high school,we both quit running track and 18 focused on our favorite sports.As I said,Mia made the varsity soccer team her freshman year 19 while I played JV basketball the first two years before I moved up. We had a lot of AP classes 20 together though. Mia is really smart and was in the running for valedictorian before her injury. 21 We used to study AP US History,AP English and AP Chemistry together. Mia was awesome in. 22 the social sciences and I was pretty good in science and math,so we were good study partners. 23 24 We were also in National Honor Society together and we had a lot of fun working on 25 service projects in Rowe. In February 2012, Mia even organized a free soccer clinic for 26 underprivileged kids in the community and got a lot of her school teammates to come.After that, 27 I got to know them pretty well. Soon a group of us started going to the movies or hanging out at 28 the mall nearly every weekend if we could. Five or six of her teammates were on both the 29 Rubicon Club and Rowe High School teams with Mia,and it was interesting to hear them talk 30 about their different coaches. RHS does a great job of hiring coaches who care about their 31 players as people; my basketball coaches are awesome! Mia and her school teammates love 32 Coach O'Reilly; they said Coach O'Reilly has legit credentials and pushes them in practice, but 33 also emphasizes the importance of keeping school first and staying healthy. I took Advanced 34 Personal Fitness class under Coach O'Reilly in the fall of my junior year and I can see why Mia 35 and the other players are so impressed. Coach O'Reilly taught me a ton of stuff about nutrition, 36 health,and preventing injuries in addition to helping me stay fit in the off-season. 39 CLASSROOM LAW PRojEC C Oregon 11igh School Mock Trial Competition www.classroomlaw.org 1 2 Mia and her Rubicon teammates really like Coach Dempsey,too.They said Coach 3 Dempsey played in college and had the chance to go pro but turned it down in order to coach at 4 Rubicon. I've never met Coach Dempsey but all of the players have only positive things to say 5 about the soccer skills they've learned from him/her.They have mentioned that Coach Dempsey 6 is more serious and less of a friend than other coaches but they seem okay with that.They know 7 that winning games is more important on a club team because the reputation of the club is at 8 stake; that's the whole purpose of its existence—to win games and get college scholarships for 9 its players.They said that everyone knows that Coach Dempsey expects a lot of the players and 10 will bench them for being late to practice or pull them out if they're having a bad game,but that 11 s/he does it to make them work harder and give them a better chance of getting a scholarship. 12 13 However, some kids who were no longer on the top Rubicon team with Mia would 14 complain that the club was too ruthless and too quick to demote players who were having a bad 15 day.I remember Mia being upset after tryouts because her best friend got dropped down onto the 16 second team. Mia said her friend was sick during tryouts and didn't do as well as normal,so she 17 got demoted even though she had been one of the best players.Mia said she overheard the club 18 director,Jordan Reddick, saying that_s/he didn't care if the player was sick—if she couldn't 19 tough it out and do better than that in tryouts, she'd be useless in tough games,too. I clearly 20 remember Mia saying,"if the club would do that to her,would they do it to me if I had a bad 21 day?" I told Mia she was crazy to worry about it; no way would they demote Mia. But I could 22 see that it worried her,and it didn't just worry Mia.Three or four other Rubicon players nodded 23 and said that it shocked them,too. Some of the joy of the game seemed to drain out of Mia after 24 that and she often looked a bit worried if she thought she might be getting sick before a game. 25 26 Mia and I had several classes together in our junior year. We were both taking AP 27 Chemistry,AP World History, Honors Pre-Calculus—and Advanced Personal Fitness for fun. 28 With our other classes, it was a killer schedule so we were all pretty tense when it was time for 29 midterms and finals.Junior year grades are so important for getting into a good college. I knew 30 Mia was looking at several top schools—Stanford,Duke,University of North Carolina—and was 31 hoping she had the grades to get accepted and get soccer scholarships so she could afford to go. 32 It's pretty stressful to maintain top grades and keep playing sports at a high level,too. 33 34 The way our classes were structured, we all had a bunch of big tests the week right after 35 Thanksgiving. You'd think the teachers would give us a break over the holiday but that's not 36 how it works. So,in between stuffing myself with turkey and playing with my younger cousins,I 40 CLASSROOM LAW PROJECT Oregon High.School Mock Trial Competition www.classroomlaw.org I tried to study for exams. I was glad when Mia called me on Saturday afternoon to ask if I wanted 2 to go to a movie with her and a bunch of other kids. Of course I jumped at the chance and even 3 suggested we meet for coffee at beforehand. When I got to the coffeehouse, Mia was already 4 there along with five of her teammates,all Rubicon players. I knew I was in for a lot of soccer 5 gossip but it beat talking about dinosaurs with my cousins.The others were excited because the 6 big College Showcase tournament was only a week away. Mia said she had heard that coaches 7 from all the schools she cared about were going to be there so she wanted to do her best. She said 8 she was looking forward to practice that week because she knew it would help her be prepared 9 when the games started on the weekend.They all chatted about soccer some more,and we all 10 complained about our big tests,and then we went and enjoyed our movie. 11 12 On Monday we had our Honors Pre-Calc exam; both Mia and I felt like we had aced it. 13 One down,three more to go! Mia said she was glad for the chance to run around at practice to 14 blow off steam. But Tuesday when she got to our Advanced Personal Fitness class, she seemed 15 different,quieter than usual and kind of"down." I asked her what was wrong and at first she 16 said,"nothing; nothing's wrong." But when she looked uncoordinated in Zumba and asked to sit 17 out part-way through,I asked her again. She told me she had a bit of a headache and asked if I 18 had any medicine so,I gave her some ibuprofen. When we were walking to AP Chemistry after 19 APF,I asked if she was feeling any better. She said, "no,not really." When I asked her if the 20 headache came from the stress of all our tests, she said,"maybe that's part of it,but mostly I 21 think it's because I tripped in practice last night and hit my head really hard when I fell. Do you 22 remember the concussion I got last spring? I'm feeling a bit like I did then,sort of woozy and out 23 of it.I started getting the headache last night." I asked her if she told her mom/dad or anyone 24 about hitting her head and she said, "are you kidding? If I did,they wouldn't let me play in the 25 Showcase. I have to play; it's my big chance. You know I can't afford college without a 26 scholarship. Promise you won't tell anyone about this!" I must have looked concerned— because 27 I was. I'd read the posters Coach O'Reilly had posted in the gym. She grabbed my arm hard and 28 said,"I mean it! Promise me you won't tell anyone!! Not anyone!!!"Reluctantly,I promised. 29 30 After the AP Chem exam, Mia rushed right out before I could speak with her again. I 31 tried calling her that evening to check on her because I knew she didn't have soccer practice but 32 she didn't answer her phone or my texts. We didn't have any classes together on Wednesday so 33 the next time I saw her was in APF class on Thursday. But as soon as she got there,I saw her 34 talking with Coach O'Reilly and, next thing I knew,Coach O'Reilly gave Mia a library pass and 35 Mia left. I thought about saying something to Coach O'Reilly but I didn't want to"rat" Mia out. 36 And anyway,I wasn't positive of the reason why she left class,so I didn't want to cost her a 41 CLASSROOM LAW PROJLCT Oregon High School Mock Trial Competition www.classroomlaw.org 1 chance to play if she was feeling better. I figured she knew what to look out for since she'd had a 2 concussion before and I tried to put it out of my mind. 3 4 Mia seemed to avoid looking at me in AP Chem and she rushed out the door as soon as 5 class was finished. On Friday she looked pretty groggy when she got to AP World History and 6 she kept rubbing her head during the exam. I tried to talk with her on the way out the door but 7 she just glared at me and said, "remember your promise!"Against my better judgment, I kept 8 quiet. I should have told Coach O'Reilly or called Mia's parent,but I thought that a friend 9 wouldn't rat on a friend. Now I have to live with knowing that,if I'd told someone,maybe Mia 10 wouldn't have played and maybe she'd still be okay. From the way she acted,I'm sure she I I suspected she had gotten a concussion. And given the look in her eyes and the way she grabbed 12 my arm when she made me promise to keep silent,I am positive she tried to hide it from Coach 13 Dempsey and Mr./Ms. Perez. But I knew,and I should have done something about it. 14 15 I feel truly awful that Mia is injured and I hope nothing like this ever happens to any 16 other athlete,anywhere. I remember a bunch of news stories about football players who got 17 seriously injured or even died after suffering repeat concussions. I never dreamed something like 18 that could happen to one of my close friends. But it still doesn't seem fair to hold Coach 19 Dempsey or the soccer club responsible. I've never met either Coach Dempsey or Jordan 20 Reddick. But I do think that if Mia was able to hide her symptoms from her parent,how could 21 anyone expect Coach Dempsey or Jordan Reddick to know? 22 23 Of the exhibits in this case,I am familiar with the CDC High School Athletes' Signs and 24 Symptoms Poster. 25 26 I hereby attest to having read the above statement and swear or affirm it to be my own. I 27 also swear or affirm to the truthfulness of its content. Before giving this statement,I was told it 28 should contain all relevant testimony,and I followed those instructions. I also understand that I 29 can and must update this affidavit if anything new occurs to me until the moment before I testify 30 in this case. 31 Chris Durant 32 Chris Durant 33 34 Subscribed and sworn before me on this day,the 27'of August,2013.. 35 Beth. EckkardE 36 Beth Eckhardt,Notary Public 42 CLASSROOM LAW PROJr?c;I Oregon High School Mock Trial Competition www.classroomlaw.org EXHIBIT 1: Acute Concussion Evaluation (ACE) Physician/Clinician (Page 1 of 2) Acura Corcusseom EwumAnoti(ACE) peter,MIME 4.0141....144w.r , ---- PHYMAN1.1.01.41 OFFICE Venison Om: 414/ Orprord Wok.PAO'II Rhin CONns,POO, Vieisol talliflai OMNI Colfils 0 _51.11 I Z 11:0111101_114 141 •onsimaror wows.mow telaW 4 ,.......... A jnitytheMidika Delftbits al way_ 1 0 0 n4.1/ J11_,_ftwaer .:1.Fillso_froscal_Rookos_011ww,,_ I.*wry anorIoNso_Ini.Attilaimaiwt_saLIA441x.4nOrt.,.,,,-'„)r-Ier)is Ada 1:41..smAirii.,_gortii h.J amid%..._....... , —ippasity-41-44.404.4--41.1_1 4 ra to—it a.2 a 1...4 i bucck Avia.becioteitak_c_441 4.1*mit la is tilos avombeataloodwitor btu'Mod WWI or irdrop icvar ,,Ito _LkAnown 1%.n Iwo Moms wt Inloosonhil9Nry kr alwol kinsww? Yok .414n _Unknown In,Locolto of Moak_From, LL*lOvorwO _It Tompoirt _IA NAM _JR/WNW _OoatIOI jack _„Whoa Flow 2.Qom_INC_Po440fon4AVC „Jell _Amu. fr.Roods weig_Alutte„,,,_,,,_mot _ &Ranoildlningo risoorods.Me too any OM.kw/BEFORE Swiriloy Oil"oaf poor On;wo sionotO Noon IAN; Liti;._No tookin 14 oh. 4.fonsdaMat(Annweanda)Am tot ant ofilaril Oat A/7E01 I*krAwy Rd ormiposow No no onormay 0 Nom%AMP _ s jj4o Oman IL Na •On vont parson loss corockkoowook7 _Yos!OOP WOW E.EARLY(NOM_Avows eland alumna .,,nowdralot that Irma„..Mows rporlkorsk Ow*_Nom*Ckailara __ForoOkt Peon*OM 7. NNS:Wan Miura abosnower PeajNos_.DOW, ,,, .„.........______________ Ilkarigeggichollakit, Sem IN hprty,hos we prom ow/0nm gm at Voss 0,04000*NV NINIENIUMIN IINAIPm 6 64 MR N/WP Indio%prielltat of omit orronnow(a..No.10%4 Um/A CMOs 0110 RINI PIIIICAL(f I) NEE moan(4) SAW pi —7.101TddlChO 111MI iiiirc food*tior IL? I Otorivess Nwoork fou paini-ik„,,,d- ....v Ko I 041.1 Ism' Vomomol I * —-.„ Vortilwe up 011barny otrorfralng 0 7.3 2101.20.MO lkor woe !" I bermoirsooliriinT nix , 10 I iii;oto wog arm ---iM) lei' ,,,..... 01121now nitin colitiiii tow, , .....,, ourr,?2,4m.,,„ Vlotalima000-;--cjim oe10111114(4) follos 0 011 Maw 1111111200 00 0107010spos juin opt 1100.01/1600 ir i ____,0 I C141/16.NW*Vim _Ito_IIVe . .- Serval*lo nabs EJ i re I demi 111011.611.1111011110 00 pow sift Numireseliglop imi Iiiroxems0 , 1— sloasPel 10 Naha,era rolit SW* WAN&totillp441) 1111107100AL IMO IMO _ Nemo a ep $ a a a val paaama (Ali 21401•0.'sp .,000140,am ...., ...._ „.,...„... 1.00 Owe ;..,,, ,„ __,..._ . .. Si Nom tor '"!'"*"erwr - ocoot a ofor*woo C40800000 V, ,„, i ;* IS Y N_ . plmx•• I 2 I 4 I 0+ $ Ng Osatveril he Imaische WNW.amill144 I Au*, Wool sprilIss*mon' *Mr,al sitipahte larook0he 20.48.0020' • pirTimmors Daps_Ws0m_Moon ,Yew_ Psuone 140010000/Conwor i,....moor ,.....=.---...---.p„ II .1.oweasions.N.4-Iirros ,...„,_,._ - -Os..-AworInwornik.4 Olrar poonliklo drwswItn $ oiku rairipty7 Vic_No_ UN ,tenwoOld radon dotkOws or inodcolon imp Ow.tkellonii.aniumL.„„_ ,.. .11:1111/ 1112//AmmemagLaimommt Ni 0'lc r*0001,1,02 00220101,10/2111111101100101avel fa kabg, •Nrodorrao osi nernOt •UMW MN Omni owl So aminsul •on mood.moot,plugs •now%pie •lIslooso •04•00,0 WINN •Irowdira awillow et Wow, •stom001060,110*NW •Pall trwalso sym •Iwo masa •wrimm•amosus 01 anskrag •Oloseitosestistrommums n ; LIMMIrtarcusico o LOC Ivan_Consowlon nI LOC MI _,Cempampo 0.0aps01160 NU_Omer Iiiii="1.7w _No Owe* F. . . - — - 7..77 •• - 0011 /111. 018181*116110Mse esalsoing Ow et arm ledcar,up, _ ____21Wroprecholog021 irlIng _If*Mae Namosur‘wy_Nftwo/sof,,...,,10405 Moildrii__24010001____20001100t_Celt_ Errnwannoy Dignowit — ACE Compleisd by: .140,a4.....315,0..„ *copy,4 044$sat 011oma 10011 Me two Os.0 911aul yr 001,1040 war"rgivelmotatilmiorirsmOrm foresertervisefastsinla 43 cl„A ssRoom LAW Pitoj ECT Oregon High School Mock Trial Competition www.classroomlaw.org EXHIBIT 1: Acute Concussion Evaluation (ACE) Physician/Clinician (Page 2 of 2) dlieeeemineAmeeldbeumellpjwilkaleaaani a a ccaaprw patnopfyta4lopam proms sesang Me brim,mused by twarmafc blaraelnwricM hones secondary b tend or indirect tames to ft lad.Disturbs**s**al brain imam is malt to neuromemboie dyatiawyion,nerd Own n uav a Mary, and a type*aauocend ant normal ainavrad nsawtanaphng andnnnge(ee..CT each hello.Canrxauean may or may not ogee a loss of oanecicanses (LOC).Commas mats in a mn.wwkr,d physical.ergela..malionel.and slog-rsdard sympterrr..Dye 1e may at from several muss to easy.,ages,manta or wan longer in same cares. ACE trrtiersrn The Amos mimosa b poise an evidence-Weed caw*prdecol to conduct an raid evakua.wt and diagnose of Measure Oat chador sod galls) eel krnrrn a au.pecled UTlil.The meouch addax.decunwaing to importance of U .eorporerus in te eveltaefdn of an MIDI is armada n the awing lig 1.OlIaii .Ma:Fry acct md,type of Mice,Ocala on the Mad or body(If force wararei ed b heal).Diemen bremad+rrp of i$sy nay mull in dOloonOel symptom peens(e-g.,occipital odor may mod in visual comps,biome daecula pi 2.Indicate tM tltur.01 b$cat.fame.fora.s easociaaed,at the*arrive are ik.y b maul in mate seam paee.aren d erapbm.. �.Nicallu:Atmeri.is afoot as to bike*m Win new memories D.Mrrrtaa whether deemse toe amend and agog b detannire lrhph of woe of memory dyska nceen-dtlotM('staged.)and dal eL.(wnl'oprwa)injury Even seconds to ratan M memory by can be preolts ve d arbors.Rawl reeeeeh has indicated Mat amnesia may be up to 4,10 arose mom pneaelMe d symptoms and mgnYlre do a s baNraing as:ammo thank LOC Om tarn I minute(' 5.LaggAiggiggliggiggs(LOC)-M amrs,donna*length of LOC. S.ialb age. If parrs.ask Is individuals oft know ties osiers(p.rsa mouse.hi.ncl,etc)aeeut specific sips.of Me concussion that may hew been Ibsen el Therm signs ors typically obeerveo early War the Posy. 7.kname ersinnor nYhela wan claimed or not ,.Aak giant(,adwr eaui+t,if shad)to impart,mom=of we four cVSgoi es of symptoms sing injury y It::rrp�arterd to a.eeeya(at glad is as offerers pas d to Wolin areal d6nna b .Cox tar sM lopvirea"'a/be�depending r gds of awry Rag'V tor Vas �r or 111-_ror No to tar presence Cn absence. 'iee� rW 2.For all . p Banc.d i ito a as.rpra.rad widen Mme bas 24 hog.Since ay.'Otis ton to pomiant prerrr al brag* (54.deasnion,heedacAas,slap,senses),it is agorae to assn lappb,!!om tree ustet preamlaOWL 3.kmriar Biro toed ouOgar of marabout mesa per area,ar.d sun all tour moot sues Tbww Syrnptoen Score(.mar.ramp 0-22).(Ut.:muss slog a me to.a ant err appiioaefe able Ai nips has passed Was tar inMry.Dourness may ha present an the day al:stay.)M amnnplase an new and pens,rare a M lover tins.ynpan amore,My tmfasfl indicates pagggingiugg tewory. 4.fraofos hooey wbeta any ammonia worsen with ohy.icei(e.g.,moving, o airs,bike riding)emits aagriwe iui•..cedan m,darts. mata-dailang al aork.Mang Or otsr reds musing lofted aomcwmSIcie).reign.Carscaes stand be swore that sympmaw ft typically worsen a m.raga writ seamen,indicainp raerirl maw"Oarartion may protract tecc soy. 5. Oelrmne how dUbrsrt dot paean is Aiding from Main till all.Chola'0'(Normal)b'6'(Way Di.rar). Assess ris baOvMp neat taetea as egaba carrptcadiril tastes in the rscavery Rrtacna. 1jkoloolioghilom Assess the mantis and cias(e)d per oane mime,to duration of sordloms for each injury.end MMWer due bioracheneai live aloft'tan r wy Ressarcie'Made*ft wpm*Hi symptom sheds of COmaslaedn maybe unaisaa,eapemlaly t tee a mental daahon d tea began irljtales rd lent biontocherical lode rags n auheeearM casts ion(which may it cell kmampVa mom"earn Atli trau ms).'' 2..11aggagb UWM y Assess perm,*amdrer aemly hirmy d aisgnasiftsa nr i In hniaefwra.Research endimeea inaadtde(retrains be p.rticiir) man moult be wafted recovery bum concrwabn.' Igaglgaphsplatbigga Arises treaty of fuming dieb7iYaw A AWMien.AelrO types drily Dinar or eMrdeasioprt ardal.Muds..Reseal* iwtcaw net Mara ie Ow pcsstaty a a sang.r pared al rsodvery etas Male conditions" 4.211fibildolimar A.....tar Wray of dopm.:oMnoda reedier,anxiety:artdfor mama eracrtde..a,. 0jbatElaps.the pt.eee should be wrests)observed air the first 244$Mum Mir*ft swift sigma Rad Rego em to be mama as pp ity_ getgaggegmagagmigigitagggigg Any peeve wed staid prompt strong awa+d eition of nerved for emergency medcel evaluation(age CT Scan b rule out inaaartial Mead or ohm airman*pagitiogyr dMippMli:T e toliftrig SCO the apmcattc codes may Ott applicable KO 0(Cane sabara,with so been of aorrdduAirwae) Pa.itiue injury awip&On math.et.n .of forcible air sat'indirect Mow Solna Mad(Ala):pits evidence d achy.symptom(0)d any type and number ber role sd b Me amens(Taal Davos Sass's0),no agleam of LOC(A5),Orin f/acte.se or Morai*N glary(Ash). $50.1(Cs neusatca.with brief has M aMtoiwwe.e e 1 hear) Bestirs irrjrary description with avian=n=of arable dimeV indirect Nora to the heal (Ala):pea waft=of salve symptom(8)at any type and mortar Meted to the trauma Oft Symptom Soft r poarua o idetws of LOC(AS), skull Nachos d irvaararial injury(Alb). Ke S(Cerxaealen,wepeoihd)..Pinata be ury descration with.vidanea of tenseo dine i farct Wow to Si.heed(Atha):plus agin■of gag aympbm a(e)of any type and reanbr maenad to the trauma(Total Symptom Sroare.0);u•deerharmdan wavy daces:unclear evidance Air LOC(A),rep rsA hneaim Of irteraerrnirf injury. Odor oleposes-t re arrant pneeened sal a poem**Ivy dsamrplan and.nodeled%sno a.but aodagrat oaken=at insrecnt j May(A lb) such es fan eetage girp,a macerate TAI and the di.pmowic category of$54(imiamarrii irt)iay)should be oetwitw.d.. Ejallogakagggagor Develop a let plan d sche n for symptomatic patients.The phys an:fir n;awe may deride to(1)mania to pot arm in the Oka or(2)weir that is a swag.sera evakaatton of the woman a checr as symptoms may neoan,worsen,or ad and doer diwndtng a man miry%dors(aA ooirOhnionrkal wemheet.,contrlydIss).Referral tae spaci,eiiaa con he p.rliatardy wuuable to yelp nonage osrlim aspects of tM paaenrs condign,(Ptrys+ienfOt edar ah0ltd also amylae Ti.ACE Cwt Phan nude dad nn see add at) 1.Ployeasienelnialan aerial sitaidloring ly aatprapriil t number ad e.teriy d.rrpaona a Macey deraaasitp over tins arid'or key roam wig'n 2-6 days.If a ady athid on is not avid.t,edemas b a aortae is vienarlyd. 2.ROOM td•apaelMet-Ap rci,t e t srrolom macaw I not Smile in 3-5 days.cc serer it symptom pall c onp slag me rypNaavway. • SieggyagggyggEstjeattg an provide valuabl idonnaticm to help amt a a peli.nta ixait andiron and w4rirnrent and raft with snorers planning.such as Men to pay caftans, • E�tan.EEgaltttlp a is ptrtici.Uty rafts*Mir medical.verist ant srapane t of csnar.intr.k ire ale critical it awed sing and swaging local naeaolipio.smeary,vVObulr,and comer causmr..It may be maul In maaioalion ma agrmwr(mg.,Modem* s.deep diagram*, deprsewdn)M per-aancataarte Maw*persist. 44 CLASSROOM LAW PROJECT Oregon High School Mock'Irial Competition www-classroomlaw.org EXHIBIT 2: Acute Concussion Evaluation (ACE) Care Plan (Page 1 of 2) Acute CONCUSSION EIALUAT1014(ACE) Mere tone;. 'r►"t sk._?!cteey.. Oaths wow a 1Noky webs.PK, ewwrtwr�rwrwtta,r Oeeo: •f J t l it l _ wr.,ar.r err.*r1.rar Over, !sate d You have been dagnaead with a concussion(atao known as a mild lraciadc btein kjury),11*pateona plan Is bawd on your symptoms and M designed to hs speed your recovery.Mum cwsruf Mention to M can also prevent lunfur eery. You should not partialptls in any high risk activities(e.g..sports,tad education(11S),Ming a boa,Iec.)M you a� have any of the emplane!slow.N M khhpotted b knit acdvMee Mat Awoke a lot d Mtrtdep or conowerdan(hoMa .1k, Job-r lc sd acih ides),as the can also nwlte your symptoms worse.it you no longer has any aynlltioms and bairn Mat your concentration and thirrwng are bade to mend,you can.iarwy and oEPAM ratan b your day acMlis.Children and laaregers wig need help from their parents teachers,aaadrR or athletic bakers b hap manes Met raeovery and return b sothilies the taia.tg emplane are p...rer(abate or weak). _No tepened symmete tlealeng tta diewal Weddle. Mrat� ±+errb boom oraawwa ..._......w....._..._. .. . M_...._._. .._____ Nouns sanity ty ht noise Radon*cmmo nlming 8adtaes ar..rwrg.ow!tan aa.i Fatigue J INaainsss'TIngi g Pocttlor»wmanosdhp wF'sa"M maw moor. esspinp bas then sei.l Visual pnttesnr Wn* Fame mere soma dawn wormarsas 'innate Ime mienP EMMsrhssPrarisss tJfesirhrrs �_ _� . .,_.._�__.-_____._ 1.• RED NAM Cul your doctor w go to your sear,.nor deprinerr 1 yes awtwr eeedeaee aer a rs folic wq CO uue c sa+mem Leek my&num ern tonrni.tad Cortocao ieOm*wn.ows Ungava betaiior dump W Sabana 1- - oonrp ° "rrw► srorrreYrpirare� Neck ulti erase!gams wrw.wserrsensesr,ore reOu tooeleoudrusru O s t Get ins of reft Is auto to gat enough imp at nlgt-no Isla nights.Kemp the earn bedtime ermines and weekends co2.Tike daytime nape or rest breaks Mean you feel Bred or Wpued. I s activity yaw wait as activities lanes squire.lot of LItdag or rt.Tessa arehena ear male• Physicl adleity krcb,dss PE,sports pnoioas,weight-baiting,twin" heavy Rau arc. • Thinking and concentration as le..g.,homework,cimework bed,lobestrMd roSveyl. 4.Drink late of Odds and sat carbohydrates or protein b mein apprgnibs blood sugr been 5. symptoms decrease,you begin b Symptom worsen or � issen you � spi to Increase your scerities pidually. e.tuning recover%it is nonmat b feel trust/Wed and sad when you do net feel right Ind you cant be ere ace as meat. 7 flapeatd ireduellon of your aymhfMOnnre Is raaonn.nded to NO prlde recovery. Beimminglailahaal I,It yds(or your dikt) adi hewing symptoms of rencusalon you may need sea help to plod=adoaFre As your(or yourchits).rre:oma demean doing recovery,the sea 'w supper*can be removed paduelf 2.inform M>e teac►w(a),achod name,scrod mythologist err aaus.lor, and ac10 nlwaronta)about your for your ddkili) injury and symptoms School personnel should be In trtuolyd to_- for • increased problem»paying nieneon orranoatrern g • increased problems nnertodlang re yarning now wormeiion • Longer 11ns needed 10 Cont**Wks Or asstarnamts • +Graalr ineabtty,ties able to Dope wit drew • Symptonne wanton(e.g.,headache.WsdneM)wean doing adooM.o.lk .......................................... ..............-tya..... . tnatppr............_.___... .................., at w.a t+rr.rrrlrrw tut:W*PAW,wwrwrsrrw.wrr ytr0 tarn ri...taw.,.+rw.r.pwpt 45 CLASSROOM LAW PROJECT Cl' Oregon High School Mock"Trial Competition www.classroomlaw.org EXHIBIT 2: Acute Concussion Evaluation (ACE) Care Plan (Page 2 of 2) ................. ......... ............ ........ Ailumlogitachoaftsmilnued) Uinta you(or your child)hem fully recovered,the'following supports are moommendect(check ea Mal apply) _No moon to school.Return on(MO)_ . _Return to school yeah Wooing supports.Revise on(ms) _Shorisned dey.Recommend hours per day until(Wes) _Shortened claims(t.s- it breaks during dense).biudroum dem isesfh: ______Wrens@ _Mow extra One to oonernie commardsesipments sod tests. homework Iced by S.11Aeadmum le ngth of reyley homework 2NLiolnel;Scant classroom or saindardbed team at Mis ICheck or the Mum of symptoms(use symptom ebb on front pegs of this tern)when doing meas.the mqvAny s lot of mention or concentration. .11_1k.rest Mats during the day rur needed Request mooting of 504 or School Mensgernerd Teem to acts this pen and needed swore- a1161011011.111A1120 1. 0. • 1441 ; ,,a■ • • +,+ (Se sum thud you do not hem emploss at rest end' while doing any physical ecthey ander mule a lot al dieing or 2.$o sure Let the PE lesclue coech,endlor athletic Mime ere mars of your injury and ernplonst &k enamel to toil handed,sad and men wary bemuse you cannot Mtn to sports right serseWth any irgey,a lull recinery wil reduce the chances of geeing hurt win.Itli bolo to miss one or two rem then eve shot@ seam& Do not to P,1411111WallirMin"tiaMILIPM11111111111KSPIUM ChM at Ills time Return to PE class Do not relurn to sports precdcesternes at the lime MEW return to sports practices weer the supervision of an appecehis heal)are provider. • Return to pley should occur In goduldialga beginning solth amble~dee coty to borers yaw keen rate (eg.,elsoonery cde);using to increasing your heart rate with movement fog.,mud*then addhig conieled °meat K epproprialm and finely return to sports compselon, • Pay careful Miendon et your symptoms end your Writing and comenheace sidle at esdy stags of WM*Mao to the nod Not 01 Mirky only II you do not emerienoe erg symptoms at the each Met.II your .somplose mem, slop these Wham end let your heeler cars moleseend to Once you hero not mpsrimosd symptoms for• minknum 01 24 hours end Ism maim remission from your Maly cms prolledonst,you Mould Mot sail at the proton;shop of the return to play pion. Ildurniallgyike t 140 physical scatty 2.tow Mels of plveical wavily(1.0..)..This Maude'maim light jogging.Iota sisflonery biking light velgtallins(bow weight higher Ws.no bond.no*W ). 3.Modstale hmis of physics@ eckyky wi bodoinsed moyersent This Wedse morisam jogging,brief running.nedoelie- Intosity stationery did%mcciersioiniensity mistaking(re*osdtha.anafar named might tam your typed scullm). 4.Heavy non-casect physical activity.Title includes sprinktprrunning,high-Womb/mmionery biking resew nelshilit. ing routine,ran-cordite*sportipeclic dale(in 3*MN ci movement). 5.RAI contact In°onboard practice 6 RI contact In gems play lisuropsytrelegkri loft see garbs valuable Inloremien le oriel plipleiene tele IseslemeW ellesvems,so*as aeon Ow gest dadelesse nye Werra'plan is based on lottsyls erne vi Return to Ws olio.Oeloirkne, ..1_01L.pen__54.X.E11.2- _,Refer to Neurneursitry otoy Spore Meals Physimbi _Psychiatrist__Other__ Raw for neuropsychologicol IMMO ACE Cars Men compiled a. afr PIO An licompeps Oft&IA,Crew MI 46 CLASSROOM LAW PROJ ECT Oregon High School Mock Trial Competition www.classroomlaw.org .............. EXHIBIT 3: CDC Facts About Concussion and Brain Injury(Page 1 of 1) Facts about Concussion and Brain Injury About Concussion A c ncusslon is a type of traumatic brain Injury(TBl)caused by a lump,blow,or}Ott to the head.Concussions can also occur from a fall or a blow to the body that causes the head and brain to move quickly back and forth.Doctors may describe a concussion as a"mad"brain injury because concussions are usually not life-threatening.Even so, their effects can be serious. Concussion Signs and Symptoms Most people with a concussion recover qulddy and fully.But for some people,symptoms an last for days,weeks,or longer.In general,recovery may be slower among older adults,young children,and teens.Those who have had a concussion in the past are also at risk of having another one and may find that It takes longer to recover if they have another concussion.Symptoms of concussion usually fall into four categories: " " ;fit N s NN , B " I k � W ' m MS r","10 N "`0, 0 0,\‘‘ . N N Nausea or tootling Sensitivity to evict or Fee**died, Tlearly nn) tight energ ruby or Mowry v�ion I� aa�+xe f e>x \N U ,d�Ny, wS li (NM\u�1' Y+ \ Nd \� tN� d;) 1 N t‘S' a , ,d^?tt+F�^,�a �!\N\',NNPhNUMr�WM h� \� ��`�N'�,hH�NuN..,,"M,, �� N�vaNd4WH,�,Ian+V'Na%r�`dN'�'.:�'��u��,e��d,++vNr,t 000\viNNN,\N N�w'1N\'�1N� Sleeping 4.if Seep us more then OP lest than!awl Ignoble feline asleep Getting Better Rest is very important after a concussion because it helps the brain to heal.Ignoring your symptoms and trying to"tough It out"often makes symptoms worse.Be patient because healing takes time.Only when your symptoms have reduced significantly,in consultation with your doctor,should you slowly and gradually return to your daily activities,such as work or school.If your symptoms come back or you get new symptoms as you become more active,this is a sign that you are pushing yourself too hard.Stop these activities and take more time to rest and recover.As the days go by,you can expect to gradually feel better. Tips to help you get better: "„ wi \ i ,NNE • Get plenty of sleep at night,and rest during the day. • Avoid activities that are physically demanding(e.g.,sports,heavy housecleaning, a cleaning, ' working-out)or require a lot of concentration(e.g.,sustained computer use,video games). ,, • Ask your doctor when you an safety drive a car,ride a bike,or operate heavy equipment. • Do not drink alcohol.Alcohol and other drugs may slow your recovery and put you at risk of further injury. There are many people who can help you and your family as you recover fmm a concussion.You do not have to do it alone.Keep talking with your doctor,family members,and loved ones about how you are feeling,both physically and emotionally.If you do not think you are getting better,tell your doctor: For more information and resources,please visit CDC on the Web at:www.cdc.gov/Concussion. u.s.DEPARTMENT TMENT OF HEALTH AND HUMAN SERVICES Calf ` Cr nor w;icr t;rw0,8se C.'rrr rr!aH PPrrrv++ntror 47 CLASSROOM LAW PRC)f EC:T Oregon High School Mock Trial Competition www.classroomlaw_org EXHIBIT 4: Sports Concussion Fact Sheet SB721,Jenna's Law (Page I of 2) How Common c '? Sports Concussion Fact Sheet SB721 'Each c then one Jenna's Law trerassdc Main Injury.80.90% d ehich era mikt and as due b A conwuke Is an*try b Eke brain maid by a blow or Jolt bee head O/lar te=used mots yeti*atodenlR Mt, for concussion include mild 3fa___brash minor_how Imintsdfsisty •The awed Wen fru Dews fotowbp a concussion,a piton nusyr 61 wwral 4 ss a/s pb Owe*noir Caned and Newton we ae csoritivo,physical ar aaeeimN kutdioninlp.Sroplews can wry kw one person b madly, moot• n sports and and can last for minutia,ham or waft asst a conwition. natMias•ra4rd=outs ws node awry yea.b aparle Recovery from Concussion abree•300.000 carnanabna In Recovery from concussOn can be dooms for every Pavan.*mint n t earn Mat from any a few caniaae b or 01 a s Winded b occur weeks she ores canueaior�Long-awing awoken can ittertan vat i a chid or addeacant's pe fornerrce oachoci,a oath•concussions om occur in a tvirie limit self participation ei scales al hone or in Mee canrnuniy.Therefore.*is nod**b ayelenrallcdy•value!.and vanity d also%kecMbing(but any may aynnpbre>s not frMed b)babel,hockey, Football a""1►h01 •Foothill Injuries eaaodwrd vrtke the brain owu at a nee d one in ray 3.5 porno. �, •Footeal I responsible b more rw►250000 heed injulea in the dolled Sewer-in any pen season 20%de high •.rain ryirrtaa auto more deeaee •salad players*Main brain injures and*lest Ma ad dig. teen any Oteer NM Y•In Footed pleyae*eh brain feud*are in brass more 11My b suntan new Injuries. iodine,brain Iniu y accounts fa Snow Sys 85 to 15%dell banes. The high prose aidig data al Sonny Bono and MOW ice ody in 1908,and raw Nwehe Wanton in 2001. Did You Know: hod loawareneas and vapors on see head b sewtwIrnsls and nano iramedi de nedicel Amnion in an sports. •88,111 repaais of head injuries sulWned ante Wing cc want cretin prewar!b Eft from 2004.2010 •r, K ore moo •Mmes have the highest rare.at 18.8%artatatrported head*Us,anoaaoerdem(51.9%),and young Was oarrnon typo of brain between tee ages(111.1/(41.1%)most Bay b be injured. •suieniaas do NOT Too many kids m returning to the playing fold too soon after a concussion. ie Ic ba aaoreecousneta. •fa%of orgim ed spons'"lird Injuries ecaatJJdnp practices h(Journal dAteeticToni g). •You can $al a concussion •41%of concussed Metes returned le pay too sow,Man abides concussion symptoms,such as drams Or awn M you do NOT hit your natant last longer seen 15 mules,he should be bencharl uMN he's been sptrplom free fora nook.(M Menem heed.M indied blow •Gib has a higher lnct no° e of concussion then boys.In acme spats payed by ban aret owscarily non a onewhare an b hiplw risk of gslWg burl Inc hued and cause a • school doacnt:femoM atlases*flood atrraa 40%more eons tan mobs(femme pews suer some t ehslsiori d the bran. 29,000 manakins anoraty,melee haw 21,000). •!onus oonb the bs can hoe •High school balebaif:Tomsk coo:unions went neat'240%tight(pie gat 13,000 concueo.Ons prying uamadabve and krp to ng°I •basket*boys 4' la pHs'spitball and&galantinesn w bombe&mac than half of concussed dews reamed b play too soon •Conanaions Iyplcsly do NOT (iownal dAthiaic Training). apptar b neuvoimrgig lfudiee Mandatory Annual Coach i Reims,Training on Sports Concussion much as AIRI Or CAT Sena. •C„ty youth scions coaches we rsquisd b haw a nual Paining b spot did abuse,bit not for sports oa�aamNon •Durig 20014005,d>tdmn and •Provide aims trai mp lha gh ahtree aid corneunia resources such as Caller br Ch ante Coned(CDC),8IAOR, Kea apt 5.18 yeas local hospitals and oleer roc-wits ama►rred for 2.4 rtMitarn'ram' •Ranrhe a diid from(clay M Ihy hove coloration mynpbmt bat Least 8 dayfuay cannot retim 10 pay sMhart h eminency y r % •meteors prdessiahets rehear (135.000) wreak a i thole%. Pastel and studalto over 12 read ad sign bra On the signs 8 synlpbn*of carieusabn •Among clairte aid youlu ages SB 121 Jenna's Law 5.18 Peert tee to baring se 721 a pmdst to provision cis 2000 bee caw'w si weer bit mgui s public school conchal and ramss to aparto oe taerealond woad*Went ataeles from brain injury. SB 121 adds torches and minus fa dub and recisions(Mace•trot aee•Mies,440*oast far *to mull gel rawly hiring on contusion,awake must keep Mass who have signs of conartl©n odd � � a competition for a dry to %g_ and pet m medical sown p eond acsrRies, Jaw Snort a foereer rhrrrrpiai sus roar,IOW sulfating repealed concussions as a alder,soften payer and cocoa savant. playa.tea deposed with garment brain Omega. She racalyd ahat when Mot training.u»sheg was considered a sign of had dots, steer concha had*coveted be synrpbnee of s aucuaton•she tour_have bean opened serous injury.'We need to prowl to kids from a lie hip from be mime pain teat I did.'ahe old. tar molhsr.Ronda Snow Mu tit Jenne'night here a gold nodal,but she hes to brain Oa 80•yew dot Wire riraim.• 48 CLAssRoOM LAW PRO)EOF Oregon High School Mock Trial Competition www.classroomlaw.org EXHIBIT 4: Sports Concussion Fact Sheet SB721,Jenna's Law (Page 2 of 2) Why are girls hurt more than boys Why is playing sports with concussion Of courw,nervy girt sun a up bon but rhea as ansice al 111101111 ahwt soon why they are more day b ara two a con +nn darned_For so risky? gr damn,bolt b the nick Biggar,stronger nen nsudn can bas rraa the Oxlip a mnarnb0.atria constrict.**i19 Mood flew b M brain.Al to fwd during Imbed and berate dances d the lenses being pled in a ak�Arm a rrMbn ddarw,h ocir�ygen.al d giicaMiidr bind kin ceaeioh.According b e study tel MI be published ii the Journal d Scadclww cs.rh1 ctcundsnncs ct man's nicks b 20%Weer run Mot h ate*et energy•nPP10 Brain ding get eve rah.and■ wonrn's necks.Furrier,rennin INS scoured tar men's nods as 50% ° wdlaM hrtho cart!We a sugars cram skew rotten rove b WI wronger then rhos,of wears.Motor now bicrnedurrnl array shows rat more■ 'b a stew of oehr rte,irxinudahg arhottsrr carharraion.A durMhg�.top develop striker*stronger nods than girls do. second blow b h teed*MI lead b rinse an*m eraiclinrh and we 'Mbr•eehraloped W,dssnow boys b bsttrabeorba blow b th,heed' calcium inhemm Torrawkn podia* wrgy cubs in U brain."soli says Dr.Joseph(lerocn,a rmraurrpaaf and casriMnl b tr,Bpode David lioun,&dor atrhe Brain eery Ninth tenter at UCLA's David Concussion Prow=at Si.University of Pirsbhxg r Medical Carder. 0 h Schad d MdadieihhR A e,dard oanaredorh all crane,such an energy demrd SW it nil o ant her He errded capability of ohs brain.' The 1y gins ply mey elan make a Minna Ifauin GfrMdehhrlCZ,rrreclor Refs shy canon should be the run,re to Robert Centre a of M Sports Miedieire Rinsch t tbonsiery at the lkhivereity of Wort g Grolnb.Inn hound unit fames Oleos are more leM1r ten sae atom n and cotsustion expert,linden tht even air a mid ilel4me b lend on to lour a seta wlrh ttheIt linen bared.The ins lobs their ',a must be on of are aroma tar at New a week bosh at West the worse trek Warn.Tire was their balm.the more ik ty root and dueling exetno,before WAIN b Si.Mad.Cadu`t marn(ra:'V4fhen thmyll hl lie ground a another player. in doubt sit rherrh oui' CONC1111011 • 50%of`,sound impact syndrome incident-brain Wiry awed from a proteturo adorn b whey AM sabring inert rimy(connubial)-rasur in nat.t • Famed NO school sonar wrists suffer*nod 40%maw concussion ihen aim)29.000 auurbly).1 • Fembb high!cool teetotal playws suffer 240%more corona=than motes(13,000)-3 •conaraien rats we than doubled among ended age 8-19 pereceerng in epo li ore tumble wow and boon between 1997 and 2007,wen as pe nellcn to chore not dlr*wd 4 •• he con accounted,lion iil s waxed wsl fix Ice h ckey,el 10 per 10.0p Si?-b 11-yaencbds and 29 pee 10.000 sentient,Si 12-b 17-ysrdds.' lnrdids and 21 per 10,000 br12-b 17.year odi • Youth sport as gelling same carrpealWe,and item,b genera(are gig BarpC moo 2 art*ear a:.i•rn"+w►k tu-paParlham lle Ida tiesla ly/11tageof•tik' 1 metier t.% d r;,c xwruk R.An littnirsaulopc a„r4a«., (WHO ScAx3of Senna►savirx Sinumev m fivetftv artroexpeNkm r Aii,l Train,2044:4342):197-204, 2 0,6 RC Seed Opal widow*s.mdhw niengsmso Rut Sparlened.nrragey 14-1 r 3 Cilium,T,Saw*G.Svc Dimas end der War=of Canosient Mtn Cerepliue Adder.J Aact Trak 2003,71431236-241. 4 wow L indaw G,wow rl orwewq aenem mVMrsb Carcwea+n Yamg Crir Mori Pra4tu.2012:122421155O4 Signs and Symptoms Parents may not be limiter with concussion symptoms. Contrary to popular belief,the child does not have to lose consciousness to sustain a concussion.in tact,the majority of children do riot lose cons lowness.A chid or Wenger suspected of having a concussion should be carefully assessed for any of the faiowinp symptoms bated below. Cognitive Symptoms Physical Symptoms Emotional P en Headaches y Problems remembering Vacant stare Sad Dihfaslty blowing conversalon Appears dazed or stunned notability Answers questions slowly f irdes' Personality changes Asks same question repeatedly Ciunatineaalleance problems Ploys less Menaly foggy Furzyii llerryr*ion Sleeps more or tees ten atrial Appears fatigued,tired or sleepy VaniwngnNaueee Concussion Evaluation Appropriate eveuatim and management are the keys to a safe aukonte.The symptoms of a concussion can cause patterns when the chid reams to school,home or coemxunity activities. The concussion evaluation assesses poarble cognitive,emotional or physical symptoms to assist In piarring during recovery.During an evaluation,a child is given teats of Martian,memory and speed. Test are used to deism**any needed irdervenlions,as welt as pion for rearm to school,,port,and other physioa 49 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroonllaw.org EXHIBIT 5: Rubicon Soccer Club Medical Consent/Waiver of Liability and Release RUBICON SOCCER CLUB Medical Cannel Waiver of Liablity and Reuse 2012.2013 M Ptir 161 ,5 9 Row balisai II WI ibb ea ) • 71 i,yr"a4- : #P o dyP c)-44-05 Woo of Plftw My Vol af • Pere I VD3-74,8- 4473 Mulad Pawn balladbat tablomar Ho Mem book lbw eyrli. Mad Ic 12/1 r' ► he Wool w �r.or torn a..►ir rlma r /7 ` ue 1 sar•I aao�rdb.wrrripapadadr.aao. aaYw,alaaa`alb okdo r.rtoar.s«rrr.Ib MOM to a bob Ay a.0 gnaw r a.ma aw4 MAN olb rr ina a.ba.a mar Imo alad alt 10 Nab balm Swag ad N I NO bay aim,&kw ad am a WM Imams ad aka*Pablo*Ow%Wilda am mg MO Milk dinframelb mat kmM NOW porlapobc Iaswarraitdiu.e *b iamb onra.id die for pima tbola NOW Obi!ma ar ~XI II Maas.rr...Nbar*mama b tromp=.railaIlaboo ailbarr.mba.rraiMll.op.MS. a MOW 0017da WNW abookoata.wnoa bioadaMOawboarraa maloolimar..r..a abo rrot.ta.pi. IoMO coma or Image=la pain tl.a.si boa Watts bait P a amp.loo...rbow saramialft..wr�� aoaap oo.aw.MINK anlrra.M1awowb Wambold bMfMMaril yaw M mealy aim o•dolo of war soso maid ay phadon,moor wawa aoxbarabpalm TlrtairMorlraA Nod a 4*WNWMM0prbMIMO* • °m ow V baba I 87 6-54—ttly O.wirlr bail. 50 Ci.Assitoom LAW PRO]ECT Oregon High School Mock Trial Competition www.classi-oomlaw.org EXHIBIT6: CDC High School Coaches' "Heads Up" Clipboard Sticker(Page 1 of 1) CDC TTWX "Wi `� 6101111,41#1**PORIM. UP ictsi N l ," A Resource for COACHES SIC;NS AND SYMPTOMS ACTION PLAN These signs and syrrcorrcc may'ridicule M you suspect that a player balsa concussion, that a concussion has occurred. you should tame the lobate( 1.111111111 111111111111 1 Remove athlete from plat! 2.EMS!athlete iswolurtted by an appropriate head care piolessetnat do not try to judge these rent s of the injtwy yourself. 3.Mort athletes pates or guidons about the blown or possible concussion and give them the fact sleet on concussion. 4_Keep the athlete out of play the dry of the 'injury.Do not return the athlete to player practice until a heakth care prafead:rat corcussiert has deared them to do so in IMPORTANT P1-:ONE;NUMEERS HO5WT ntaa+Tt t A no tM eCOMaa7/A CIwuI 1er S atrtiw arvoua 0CA For imma ate accen t„CALL$11 ��.��:FdnM ,� !"�.. r1 f"..�a��ma .�u i'n Fy'.'F"•..,. .m:g°tw�f, 1, re...:Pl,. rw..,'.p,,� . •FS' .. '. w'i^" T"NNM lowoe*400,04**MMM41., 1 -4.-,tme !...#is 4/n *WO rftfowstimen ilpf"4i$6*R 404 4.1Kritint fp" o Of ory.. WAVWr d 4P/CarICUSSION$40,4ts owit onciosion 51 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www_classroomlaw.org EXHIBIT 7: CDC High School Athlete's Signs and Symptoms Poster(Page 1 of 1) CDC I .F7,41 HfRD !JP \\\*..00/ NCUSSI N A Fact Sheet for ATHLETES WHAT IS A CONCUSSION? WHAT SHOULD I DO IF I THINK A,�e is a brain,inpry that I HAVE A CONCUSSION? •Is caused by a bump or blow to the head •Tell your coaches,pantries acted athletic •Can change the way your brain narrriy trainer.Never ignore a bump or blow to the works head even E you feet fine.Also,tell your •Can occur during practices or games in any coacfr one if your mean er,wire f►t a sport COwecusslor+. •Can happen even if you haven't been •Get a medical check up, doctor or health knodred out care professional with knowledge in •Can be serious even if you've just been concussion management tell you if you "�" have a conct,xsion and when you ate OK to WHAT ARE THE SYMPTOMS OF return to • A CONCUSSION? •GiVe time to get If you have had a concussion,your brake needs time to •Headache or"Pressure"in head heal 1Mole your brain is stag healing„you are •Nausea or vomiting much more likely to have a second •Balance problems or dizziness concussion.Second or later oOACUS1SiCtIS can •Double or blurry vision cause damage to your brave.h is irrrportare to • by light west.until you get approval from a doctor or •Bothered by noise heath cane pmtessionai to return to play. •Feeling sluggish.hazy foggy.or groggy •Difficulty paying attention HOW CAN I PREVENT A •Memory perms CONCUSSION? Every sport is different.but there are steps you •Does not"feel right" can take to protect y uvseif for soccer. •Follow your coach's nAes for safety and the rules of the sport •Practice good sportsmanship at all times, wrw r c, k, • , u,., F .., w wr w c;3y, F u 52 CT,ASSRC)OM LAW PRO)RC;T Oregon High School Mock"Trial Competition www.classroomlaw.org EXHIBIT 8: USYS Concussion Procedure and Protocol (Page 1 of 2) CII. Concussion Procedure and Protocol Concussion:a traumatic brain injury that interferes with normal brain function.Medically,a concussion is a complex,pathophysiological event to the brain that is induced by trauma. CONCUSSION SYMPTOMS AND MANAGEMENTAT COMPE1TTION$AND TAAININC Dbissancussisaaccad Evaluate the player and note if any of the following symptoms are present (1) Dazed look or confusion about what happened. (2) Memory difficulties. (3) Neck pain,headaches,nausea,vomiting,double vision,blurriness,ringing noise or sensitiveto sounds. (4) Short attention span. Can't keep focused. (5) Slow reaction time,slurred speech,bodily movements are lagging,fatigue,and slowly answers questions or has difficulty answering questions. (6) Abnormal physical and/or mental behavior. (7) Coordination skills are behind,ex:balancing,dirtiness,clumsiness,reaction time. Ursa r This would include the following scenarios: (1) Spine or neck injury, (2) Behavior patterns change. (3) Loss of consciousness. . '.1,1 I. • -0 f1I 1• . * • 41.15 11, 111, 11 1 wylvt� l•.1 .1'7'I• 1PS1'..141,. Focus on these areas every 5-10 min for the next 1-2 hours,without returning to any activities: (1) Balance. (2) Speech. (3) Memory. (4) Attention on topics,details. Sett Plaver r should not re-enter_comoetition.trainintsarma take in any activities for at least 24 hours. Eve 11.y1 .'.11,' 1• SW 111.11 ,111 4111 1 1 .11.15 '.1,1..1. Ih • wl ., 11, i. 1ly 53 CLASSROOM LAW PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org EXHIBIT 8: USYS Concussion Procedure and Protocol(Page 2 of 2) Sat i� .4 1 ••■ .• •.i 11=.1 44.11 •' 1 ': '1 .,''!• 1«, 1 '41 44. lithectkaugssibilitutasomagoalcubthindac 11•.1• •. 1.-,r• Iltwi r. •,•.•1 •. . M,I . 1 1 •41. „'1 4H 1 11:.11 1i• !1 ;4 11..«11 (1) The attached Concussion Notification Form is to be filled out in duplicate and signed by a team official of the player's team. (2) If the player is able to do so,have the player sign and date the Form.If the player is not able to sign,note on the player's signature line"unavailable". (3) If a parent of the player Is present,have the parent/legal guardian sign and date the Form, and give the parent one of the copies of the completed Form.If the parent/legal guardian is not present,then the team official is responsible for notifying the parent/legal guardian ASAP by phone or email and then submitting the Form to the parent/legal guardian by email or mail.When the parent/legal guardian is not present,the team offidal must make a record of how and when the parent/legai guardian was notified. The notification will indude a request for the parent/legal guardian to provide confirmation and completion of the Concussion Notification Form whether in writing or electronically. (4) The team official must also get the player's pass from the referee,and attach It to the copy of the Form retained by the team. kissidc MD,James and Karen M.Johnston MD,PhD."Retum to Play After Concussion."Collegiate Sports Medical Foundation. Volume 15,Number 6,November 2005, http//www.am oundation.arg/Kissick return to_play_afer_concussion_CJSM_2005.pdf. April 22,2011. National Federation of State High School Associations. "Suggested Guidelines for Management of Concussion in Sports". 2008 NFHS Sports Medicine Handbook(Third Edition). 2008 77-82. http://www.nfhs.org. April 21,2011. 54 CLASSROOM LAVV PROJECT Oregon High School Mock Trial Competition www.classroomlaw.org EXHIBIT 9: USYS Possible Concussion Notification (Page 1 of 2) I . .IL „• ,� • rho Gam fw Ai Mei, Possible Contusion No:nwtlon For US Youth Soccer Events Today, ,2 ,at the (insert name of event), [insert player's name)received a possible concussion during practice or competition. US Youth Soccer and Staff want to make you aware of this possibility and signs and symptoms that may arise which may require further evaluation and/or treatment. It is common for a concussed child or young adult to have one or many concussion symptoms. There are four types of symptoms:physical,cognitive,emotional,and sleep. If your daughter or son starts to show signs of these symptoms,or there any other symptoms you notice about the behavior or conduct of your son or daughter,you should consider seeking Immediate medical attention: -Memory difficulties -Neck pain -Delicate to tight or noise •Headaches that worsen -Odd behavior -Repeats the same answer or •Vomiting -Fatigued question -Focus issues -Irregular sleep -Slow reactions -Seizures Patterns -Irritability -Weakness/numbness in -Slurred speech -Less responsive than usual arms/lees Please take the necessary precautions and seek a professional medical opinion before allowing your daughter or son to participate further. Until a professional medical opinion is provided, please consider the following guidelines: • refraining from participation in any activities the day of,and the day after,the occurrence. • refraining from taking any medicine unless(1)current medicine,prescribed or authorized,is permitted to be continued to be taken,and(2)any other medicine is prescribed by a licensed health care professional, • refraining from cognitive activities requiring concentration cognitive activities such as TV,video games,computer work,and text messaging if they are causing symptoms. If you are unclear and have questions about the above symptoms,please contact a medical doctor or doctor of osteopathy who specializes in concussion treatment and management. 55 CLASSROOM LAW PRojEct' Oregon High School bock Trial Competition www.classroomlaw.org EXHIBIT 9: USYS Possible Concussion Notification (Page 2 of 2) Please be advised that a player who suffers a concussion may not return to play until there is provided a signed clearance from a medical doctor or doctor of osteopathy who specializes in concussion treatment and management. Player's Team: Age Group: Player Name: Gender: Player Signature: Date: Parent/Legal Guardian Signature: , Date: Team Official Signature: Date: By inserting my name and dote and returning this Notification Form,I confirm that i have been provided with,and acknowledge that.!have read the information contained in the Form. y returning the signed Form by mall,send it to the following address: 9220 World Cup was Frisco, TX 75034.y returning this Form by email,send it tots the following address: US Youth Soccer Notification: Yes No y yes,method and redolent:, Bsttanni Kissick MD.James and Karen M.Johnston MD,PhD. "Return to Play After Concussion."Collegiate Sports Medical Foundation. Volume 15,Number 6,November 2005. http://www.csmfoundation.org/Kissick to_play_aher concussion . C1SM�2005.pdf. April 22,2011. National Federation of State High School Associations. '"Suggested Guidelines for Management of Concussion in Sports". 2008 NFHS Sports Medicine Handbook(Third Edition). 2008 7742. http://www.nlhs.org. April 21,2011. Children's National Medical Center."Safe Concussion Outcome,Recovery&Education(SCORE) Program."Adapted by Gerard Gioia,PhD;Micky Collins,PhD;Shireen Atabaki,MD,MPH;Noel Zuckerbraun,MD,MPH.http://www.childrenspiontl,orescorc. June 27,2011. 56 CLASSROOM LAW PROj.I.:r Oregon High School Mock Trial Competition www.classroornlaw.org EXHIBIT 10: Curriculum Vitae of Dr. Sevin Register(Page 1 of 1) Bevis K.Roister,PhD,AT Curriculum Vitae EDUCATION Oregon Health Sciences University,Portland,OR Doctor of Philosophy,Sports Medicine, 1993 Dissertation:Effects of MiM Traumatic Brain Injury on Postural Stability University of Rowe,Rowe,OR Master of Science in Human Physiology/Athletic Training,1990 Thesis: The Effects of Headache on Measures ofNerrvcognition and Balance University of Rowe,Rowe,OR Bachelor of Science in Athletic Training, 1989(and Athletic Trainer/AT Certification) Minor.Nutrition EMPLOYMENT Department of Exercise and Sports Science,University of Rowe Mihalik-Marshall Distinguished Professor,2009-Present Department Clair,2003-Present Professor,2001 Present Associate Professor, 1993-2001 Director,Sport-Related Concession Research Center,2007-Present HONORS McArthur Foundation Grant,2010 Dorrance Educator of the Year Award,American College of Sports Medicine,2008 Medal for Distinguished Research,National Athletic Trainers'Association,2007 PUBLICATIONS Over 200 scholarly peer-reviewed journal articles,including: Pediatric Sport-Related Concussion(2010) Incidences and Outcomes of Soccer-Related Conclusions(2009) Advances in Sport-Related Concussion Management(2009);and Educating Coaches.Physicians,and Athletes about Concussions(2008). Over 10 textbook chapters,including: "Management of Sport Related Head In jury."In Emergency Care in Sports and Athletic Training.2011. "Head Injuries."In Foundations of Clinical Sports Medicine. 2007. 57 CLASSROOM LAW No.) Oregon High School Mock Trial Competition www.classroomlaw.org r C0 0 CZ To: Deschutes County Board of Commissioners From: Ed Keith, Deschutes County Forester Date: February 27, 2014 Re: Weed Ordinance issues for consideration Attached you will find a table of issues distilled from public comment related to the draft weed control ordinance (Chapter 8.35) which was discussed at the Board business meeting of February 5, 2014. The table lists the issue, presents a pro and con where applicable and the recommendation from staff as well as the rationale for that recommendation. a) 'a c ° Qz1 o a°'i a� 3 'cs c) 0 O O u, x 3 0 0 0 0 V• 3 N N Q c O /] a) ■ N •. O ' 7 to , U rC O) �d I.r ± N i °wr 0, O as �, E U N 4 d f/9 v U O 'O d U P4 ' U ¢ ^C 2 Z Q 5) rg- 2 'b 4) N wi y a) O •aj ° 0 p O W ° ° •° 3 soy 0 y�0., °w) 3 E - °' g °' 0 ,Q ›,c)° cd cd clli od o Ccn = cd•~ U 3 ...t.4 . m b �5' vi '. 4) 1 En N L", 6 ,i ' Q) = V v O U O U `� c 'd C U 4) a] U O W O a) 3 r. O ,", `�y ° - '. C2" 3 U O D U ai Q = 8 to c/) .5 3 = U bi ' t toE t + E o j •4 c`cs o °• H ° .4 "4 .4 = 5w c) 3 P.. ^7J5 < o < = ' H -o f� ,9E (� � Z5 3o 0 O 4) a) 11) cl o 0 a CO Z -• mt 5 4-, ) o vi aa) u7° ) d O o ci • U ° ° c '"a U a no Pi "t -- �-, U ,)) U Gl, O U ,zz- • W t,A A - pg.,,� U O c ,' " i O sue, 0 U - rn V) x •5 cA 0p- cl) ,0 0. Q .- vv)i ', c 2 17) cn � ° '� o o5 - CC 'd8 o e. 0 a) y E tg o v, ,---,._ ° i ro } ~ ;-1=U as a -E E'.a) g E a • = •S Q3 CV _,Q V� rA V] x ° o ° Q. Z w 3 'd • W Q ° ,-- N M • '0) >1 = 0] py 0) 0 _ 6 n U SEL4 at O O O 0 -o O r.. :� U C cq, U o _ 'd "C O ' .U Q N cd u u ea O cn -0 0 U 0) O "0 E 0 O O v 'b" o °2 ea E '"" ,4 eC O O 0 to 0 Q . d 5 0 0 0 ° � ~ ,2 -o a) 0 w 0, 0 8 )rc, v .. o o 0 o ,4 0 ,48000 ,0 = 0 ;578 0 O - 0) ed 0) � et 0 0 q� Q" O = Q) N Z 2 O —4 �", Z H E. 0.) Q, cnn Q. . Z F" z 54 E 0 Z et . , o o 0 U 0 6, a U 0) t et m 0 a i C.) a 0 "d -0 . U cd "C U g C) °° 0 U 0 ; U �>. 0) '0 O Q 0) U O r7'+ O '' V] E E. cd" r9 ccl r