Affidavit Exhibits 51-100 in Motion To Dismiss in Dan Snyder v. Washington City Paper and Dave McKenna

IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

DANIEL M. SNYDER,

Plaintiff,

v.

CREATIVE LOAFING, INC., CL
WASHINGTON, INC. (d/b/a
WASHINGTON CITY PAPER); and
DAVE MCKENNA,

Defendants.

Civil Action No. 2011 CA 003168 B
Judge Todd E. Edelman

Next court date: July 29, 2011
Event: Initial scheduling conference

PRAECIPE FOR CONTINUATION OF SPECIAL MOTION TO DISMISS
THE COMPLAINT: EXHIBITS 51-100 TO AFFIDAVIT OF ALIA L. SMITH, ESQ.
Due to size restrictions, Defendants have had to submit multiple filings. Please consider
this a continuation of Defendants Special Motion to Dismiss the Complaint.

Dated: June 17, 2011 Respectfully submitted,

BAKER & HOSTETLER, L.L.P.

By: /s/ Bruce D. Brown
Bruce D. Brown (D.C. Bar No. 457317)
Mark I. Bailen (D.C. Bar No. 459623)
Washington Square, Suite 1100
1050 Connecticut Avenue, N.W.
Washington, DC 20036-5304
Telephone: (202) 861-1660
Facsimile: (202) 861-1783
bbrown@bakerlaw.com;
mbailen@bakerlaw.com

LEVINE SULLIVAN KOCH & SCHULZ, L.L.P.

By: /s/ Jay Ward Brown
Seth D. Berlin (D.C. Bar No. 433611)
Jay Ward Brown (D.C. Bar No. 437686)
Alia L. Smith (D.C. Bar No. 992629)
1050 Seventeenth Street, N.W., Suite 800
Washington, D.C. 20036
Telephone: (202) 508-1100
Facsimile: (202) 861-9888
sberlin@lskslaw.com; jbrown@lskslaw.com,
asmith@lskslaw.com
Counsel for Defendant Dave McKenna
David M. Snyder (pro hac vice pending)
DAVID M. SNYDER, P.A.
1810 S. MacDill Avenue, Suite 4
Tampa, FL 33629-5960
Telephone: (813) 258-4501
Facsimile: (813) 258-4402
dmsnyder@dms-law.com

Counsel for Defendant CL Washington, Inc.

Exhibit 51

Exhibit 52

Exhibit 53

Exhibit 54

Exhibit 55

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Righting wrongs, under cover of
darkness
By HOWARD TROXLER
St. Petersburg Times, published April
25, 2001
To quote The FiIth Dimension and a
bunch oI other Iolks, let the sun shine in!
Until now, Verizon, that phone company
Iormerly known has GTE, has blocked
the release oI many documents in a state investigation
oI "slamming." Slamming is the practice oI switching
customers' long-distance company without their
permission.
Verizon kept these documents under wraps with a
state law that protects legitimate "trade secrets."
Classic examples oI trade secrets would be the recipe
to Kentucky Fried Chicken, or the Iormula Ior Diet
Coke.
Exactly how allegations oI lying and Iorgery by a
Verizon subcontractor are "trade secrets" is a good
question. Perhaps Verizon was worried that its rivals
would learn how to cheat better.
Bob Elek, a Verizon spokesman, told me the company
simply made an initial routine request to protect any
sensitive material that might arise. The existence oI
the case itselI was quite public, he pointed out: "I
wouldn't say we were hiding Irom anything. It's not
like we were saying it didn't happen."
But the devil is in the details. Now that the state
Public Service Commission has made the documents
public, the details are wonderIul reading.
The story begins in January 1998. GTE began using a
Maryland-based company, Snyder Communications

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Inc., to sell long-distance service to "ethnic"
communities. The records do not say which ethnic
groups were targeted, although one document makes
reIerence to the holiday oI Cinco de Mayo.
Complaints began at once. According to testimony,
some customer signatures were Iorged. Some names
signed to the required letter oI authorization belonged
to dead people. Apparently enough dead people were
signed up to iustiIy a "deceased" category on GTE's
Iorm Ior handing slamming complaints. (My
telephone message asking Snyder Ior comment was
not returned.)
There is nothing in the record to suggest that GTE
authorized or approved oI these practices. Just the
opposite. GTE oIIicers met with Snyder repeatedly
and imposed new policy aIter new policy. By
November 1998, GTE told Snyder to stop selling long
distance. The next month, GTE oIIicials notiIied the
state -- they turned themselves in, albeit aIter the Iact.
The state investigation conIirmed 209 cases oI
slamming. There were doubtless many more, because
most victims do not Iile complaints. By last July, the
state and the company reached a deal. The company
would not admit wrongdoing but would make a
"contribution" oI $209,000 to the state -- $1,000 Ior
each conIirmed violation.
Public Counsel Jack Shreve, who represents
customers, obiected to the deal as too lenient. AIter
all, in another slamming case, the state Iined a more
blatant oIIender $1-million.
Shreve's star witness against Verizon is R. Earl
Poucher, an analyst who calls the conIirmed slamming
cases "the tip oI the iceberg." GTE knew early on that
the problem existed, he testiIied.
Poucher recommends the maximum Iine oI $25,000 a
case. He even recommends the state consider revoking
Verizon's power to oIIer long distance.
The testimony oI current and Iormer GTE/Verizon
oIIicers is that the company responded quickly, tried
to Iix the problem, and Iinally terminated the
subcontractor and notiIied the state.
"II anything, the company believes the monetary
portion oI the settlement oIIer was too generous,
given the mitigating Iactors in this case," one Verizon
vice president testiIied.
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Maybe, maybe not. You could criticize the company
Ior not taking more drastic action sooner. But as so
oIten happens, the cover-up is even more oIIensive.
The company used a state law meant to protect
legitimate trade secrets to keep these details hidden
Irom you. Now you know anyway.
- You can reach Howard Troxler at (727) 893-8505 or at
troxler(sptimes.com.
Back to Times Columnists

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490 First Avenue South - St. Petersburg, FL 33701 - 727-893-
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Exhibit 56
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You are here: Sentinel Home Collections Regulators
Telephone Customers Still Being `Slammed'
February 03, 2002 | By Nicole Ostrow, Business Writer
Nearly three years after accusing Verizon Select Services Inc. of "slamming" consumers -- or changing their phone service
without permission -- state regulators last month accepted a $1.1 million settlement from the company.
Verizon, which was doing business as GTE Communications Corp. at the time, did not admit any wrongdoing and blamed the
problem on an overzealous telemarketer.
The case involved about 200 customers who had their phone service switched between December 1997 and September 1999.
Even so, it illustrates what consumer advocates complain is a still-pervasive problem with slamming.
The number of violations has dropped dramatically since tougher state laws took effect in 1998. Through October 2001, 136
violations were recorded in Florida, down from a high of 2,993 in 1998.
But slamming hasn't been extinguished completely, consumer advocates say, because the penalties that regulators charge
don't put a dent in the wallets of telephone companies.
They contend that regulators impose fines that are just a fraction of what state law allows and that the market for phone service
is so lucrative that phone companies view the penalties as merely a cost of doing business.
"The telephone market is a multibillion-dollar market, and everyone wants a little piece of it," said Charles Acquard, executive
director of the National Association of State Utility Consumer Advocates. The companies "sort of push the envelope on how to
gain customers."
Often, the long-distance carriers blame slamming complaints on telemarketers hired to solicit new business. The companies
say they pay the fines because it's cheaper than fighting regulators in court.
As for its watchdog role, the PSC, which regulates utilities, says it penalizes companies, but also allows them to correct their
mistakes if they are willing to do so. That process includes anti-slamming measures that protect customers in the long run.
Others with the power to fine violators include the Federal Communications Commission and Florida's attorney general.
"We've seen a decline in slamming. We've taken on some of the biggest companies out there," said Rick Moses, chief of the
PSC's bureau of service quality.
STRICT PENALTIES
The PSC says that fines and other penalties have made it costly for companies that engage in slamming. And in some cases
those fines are so high, companies would rather leave the state than write a check.
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In Verizon's case, the company was willing to pay the fine without admitting guilt. But the Office of Public Counsel objected to
the settlement proposed initially -- $209,000 -- because it thought more than 209 consumers were actually slammed by the
company, said Charlie Beck, a deputy with the public counsel's office. It went back and renegotiated the higher settlement.
Generally, for every 10 people slammed, only one will actually call the PSC to complain, he said. With Verizon, the Office of
Public Counsel estimated that more than 3,000 people were probably slammed.
"The PSC only gets the tip of the iceberg," Beck said.
Separately, last year the Florida attorney general issued a $2.6 million penalty against Verizon and its telemarketer, former
Bethesda, Md.-based Snyder Communications, which the companies paid last spring.
The Attorney General's Office said at the time that Snyder representatives forged thousands of customer signatures to switch
them to service provided by GTE. GTE was acquired by Bell Atlantic Corp. in early 2000 -- less than a year after the PSC
completed its investigation -- and the merged company was renamed Verizon.
Investigators also found GTE employees forged signatures and "used deceptive tactics" to get customers to switch service.
GTE had hired Snyder Communications in 1998 to market its long-distance service.
Snyder Communications officials could not be reached for comment.
Slamming "is not a common practice in our company," said Bob Elek, a Verizon spokesman. "We didn't admit any wrongdoing.
It was really a case more of a vendor working on our behalf who was a little overzealous."
To discourage companies from slamming consumers, four years ago Florida adopted some of the strictest penalties for
slamming nationwide, Beck said.
Under Florida law, the PSC can either fine a company up to $25,000 per complaint -- or cancel its license to do business in the
state. These penalties are set by the state Legislature, which would have to pass a new law to change them.
But in most cases brought by the PSC, those penalties are negotiated downward from a maximum of $25,000 per violation.
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(Page 3 of 4)
The average slamming fine in Florida is $1,272 per violation for first-time offenders, according to calculations by the Sun-
Sentinel using data provided by PSC officials from 1992 to the present. Prior to the Verizon case, the average slamming fine
levied by the PSC was less than $1,000 per violation. In Florida, the largest fine per violation was levied against MCI in 1997.
That was the third time the PSC charged the company with slamming. MCI paid $240,000 for six violations.
MCI, which is now part of WorldCom Inc., has policies in place to prevent slamming and penalizes employees who violate that
policy, a company official said.
PSC officials said they have raised the average fine in the past two years to about $1,500 per violation. In 2001, one first-time
offender paid $1,500 for each slamming violation. Two other companies turned in their licenses in lieu of paying fines.
STRIKING A DEAL
The PSC says the fines it issues tell only part of the story.
When slamming complaints for a particular company begin to spike, the PSC staff opens an investigation. Typically it
recommends that the governor-appointed PSC commissioners, who have the final say on utility issues, approve a $10,000 fine
for each slamming complaint for first-time offenders.
From there, the company negotiates the price down with the PSC staff. That process, regulators say, benefits customers
because it makes businesses set up anti-slamming measures.
For example, take the case of OLS Inc., fined in 2001.
The PSC originally asked the company to show why it shouldn't be fined $490,000 for 49 violations. Through negotiations, the
company proposed a settlement of $51,000, or $1,500 for each of 34 violations (15 were dropped because questions arose as
to whether they were actually slamming complaints). The company also lost its rights to sell long distance in Florida for six
months.
For the reduced fine, OLS in turn said it stopped doing business with an outside telemarketing company and moved that
operation in-house, according to information filed with the PSC. And Alpharetta, Ga.-based OLS also created a monitoring
department to randomly listen to individual telemarketing calls.
Measures like those are standard in settlements, PSC staff said. Many times companies will also set up a special toll-free
number to handle complaints from people who think their long-distance service was changed without their permission.
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(Page 4 of 4)
Charles Helein, an attorney who represents OLS, said many of the slamming complaints were unproven and contends that the
practice doesn't pay anyway.
"It's expensive and almost absurd to think these companies are engaging in something like slamming," he said. "You're going to
lose a heck of a lot more than you're going to gain by it."
Unlike what consumer groups say, Helein said, companies have no cash incentives to slam consumers. He said because long-
distance rates are so low, companies don't generally make as much in income as they pay out in fines.
Sometimes, Helein said, consumers who have been slammed can actually benefit financially. By law, they receive up to 30
days of long-distance service, under the company they were unfairly switched to, for free.
FIGHTING BACK
While companies promise to make changes, consumer advocates still say the penalty should be harsher the first time around.
The companies pay it and "they don't blink," Acquard said. "It's cheaper to pay the fine than to comply with the law in many
states."
Still, state consumer advocate Beck said Florida officials probably do a better job of tracking down slamming offenders than
most states.
"When we find stuff, we try to go after it," he said.
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Exhibit 57
Advertisement
You are here: SunSentinel.com > Collections > Psc
C6ODPPLQJ6HWWOHPHQW,QDGHTXDWH
July 14, 2000
By allowing GTE Communications Corp. to accept a light slap on the wrist to
settle allegations that the company "slammed" more than 200 Florida
telephone customers, including many in South Florida, the state's Public
Service Commission has abdicated its responsibility to consumers.
Slamming is an illegal practice in which a company switches a customer's
long-distance service provider without authorization. Some of the GTE cases
involved forging people's signatures to change their service from other
providers to GTE.
The PSC investigated GTE's marketing practices after receiving 209 slamming
complaints between December 1997 and September 1999. It found evidence of slamming in 163 cases in Miami-Dade,
Broward and Palm Beach counties. There may have been other victims who did not complain.
The settlement calls for GTE, which did not admit wrongdoing, to pay $209,000, or $1,000 per complaint. That's one-tenth the
PSC's own recommended fine of $10,000 per complaint for cases of this kind.

One reason for the leniency is that GTE blamed one of its vendors, Snyder Communications of Maryland, for the unauthorized
switches and the forgeries, saying it carried them out without GTE's knowledge. But GTE should be held responsible for what
its subcontractors do, so that's no excuse. The PSC also said the settlement was consistent with others related to first-time
slamming violations, which have generally ranged from $800 to $2,127 per violation. If that is so, then the PSC has been
abdicating its responsibility for quite some time.
Stripped of bureaucratic language, slamming is tantamount to stealing. You, the consumer, are the pawn one company uses to
steal from another, and possibly from you as well. You may still get the service you're paying for, but you get it from a company
you may not have wanted to do business with, and whose charges may be higher than those of the service provider you
thought you had. You don't even find out about the switch until you get your bill, and then only if you read it carefully.
Making matters worse is that in many cases, BellSouth takes the word of the company that the customer has authorized the
switch from, say, AT&T to GTE. The only way the customer can avoid being slammed is by asking BellSouth in advance to
"freeze" its long-distance provider.
It's a bad system. It should be fixed to require written authorization from the customer before any switch can occur. Of course,
that won't help if the company forges the customer's signature. That's why the GTE-Snyder case is serious, and why the
settlement is a farce.
Commissioners defended it, and Chairman Terry Deason said those who disagree "certainly have the right to protest." The
state Public Counsel's Office, which called the settlement insufficient, plans to do just that, and to demand a full hearing. The
state Attorney General's Office also is investigating.
If you'd like to exercise your right to protest, the PSC can be reached at 800-342-3552.
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Exhibit 58
Advertisement
You are here: SunSentinel.com > Collections > Verizon Communications
*WH&XWV$'HDO2Q)ORULGD6ODPPLQJ)LQHV
July 12, 2000 | By LESLIE HILLMAN Business Writer
Florida regulators agreed that GTE Communications Corp. should pay
$209,000 to cover allegations that it slammed more than 200 Florida residents,
including many in South Florida.
Slamming is an illegal practice in which a company switches a customer's
long-distance provider without authorization.
The Florida Public Service Commission opened an investigation into GTE's
marketing practices last year after it received 209 slamming complaints
between December 1997 and September 1999.
South Florida residents were common victims.
Of the complaints received and investigated during that time, the commission found evidence of slamming in 163 cases in
Miami-Dade, Broward and Palm Beach counties, according to commission records.
And the number of people slammed could be greater than that. The commission can count only the people who complain to it.
The $209,000 GTE offered to pay comes out to $1,000 per complaint. That figure is much less than the commission's own
recommended fine of $10,000 per complaint.

The Public Counsel's Office, which has been investigating GTE's marketing practices, said GTE is paying too little. A number of
the cases involved forging people's signatures to change their service.
"We just don't think it's appropriate," said Charlie Beck at the Public Counsel's Office. He said his office will protest the decision
and demand a full hearing.
GTE acknowledges that people were slammed. But the company said one of its vendors, a Maryland marketing company
named Snyder Communications Inc., carried out the unauthorized changes without its knowledge.
GTE, which is in the process of changing its name to Verizon Communications Inc., said it stopped using Snyder to work with
customers last year. The company said it has a "zero tolerance policy" for slamming.
Commissioners defended the GTE settlement and said they thought it was fair.
"If there are parties that feel otherwise, they certainly have the right to protest," said Commission Chairman Terry Deason.
The Attorney General's Office, which is also investigating GTE and Snyder's marketing practices, had no comment on the
settlement.
Consumers with phone complaints may contact the Public Service Commission at 800-342-3552.
Leslie Hillman can be reached at lhillman@sun-sentinel.com or 954-356-4664.

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Exhibit 59
Advertisement
You are here: SunSentinel.com > Collections > Gte
*WH6HWWOHPHQW3XW7R9RWH
July 11, 2000 | By LESLIE HILLMAN Business Writer
Florida regulators will have another chance to show how tough they want to be
on phone fraud.
The Florida Public Service Commission will vote today on a settlement from
GTE Communications Corp. to cover customer complaints that GTE changed
their long-distance phone provider without authorization, an illegal practice
known as "slamming."
The commission opened an investigation into GTE's marketing practices after
it received 209 slamming complaints between December 1997 and September
1999. A number of those cases involved forging people's signatures to change
their service.
To resolve the complaints, GTE has already paid $20,000 in direct credits to consumers. In addition, it has offered to pay
$209,000 -- or $1,000 per complaint -- to the state. That is far short of the commission's recommended fine of $10,000 per
complaint.
"The fine's not big enough," said Charlie Beck at the Public Counsel's Office, which has been investigating the case.
If the commission approves the settlement, Beck said his office probably will protest it and demand a full hearing.

GTE doesn't deny people were slammed. But the company said one of its vendors, a Maryland marketing company named
Snyder Communications Inc., carried out the unauthorized changes without its knowledge.
And GTE said it hasn't used Snyder to work with customers since November, soon after the commission opened its
investigation.
"We have a zero tolerance policy [for slamming]," said Briana Gowing at GTE, which is in the process of changing its name to
Verizon Communications Inc. GTE will admit no wrongdoing as part of its settlement offer.
Public Service Commission staff said GTE's settlement proposal is reasonable and recommended the commission approve it
today.
"What we are trying to point out to the commission is that they've fixed the problem," said Rick Moses, a commission bureau
chief. "The main thing is to get the companies into compliance [with the rules], not to extract money."
But the threat of stiff fines in Florida is part of what has won state regulators praise for taking a tough stance against slamming.
"The money is important," said Beck at the Public Counsel's Office. "It's important for deterrence."
The Attorney General's Office is also investigating the marketing practices at GTE and Snyder. Officials there said the
proposed settlement won't keep them from continuing their investigation.

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The commission will consider other phone issues today, including whether BellSouth Corp. should be allowed to keep charging
customers fees of $1.50 and 1.5 percent of their bill each time they're late.
Leslie Hillman can be reached at lhillman@sun-sentinel.com or 954-356-4664.
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Terms of Service | Privacy Policy | Index by Date | Index by Keyword

Exhibit 60

2
This report contained information that has been redacted pursuant to 5 U.S.C 552(b)(6) and (b)(7)(c) and 5 U.S.C. 552a of the Privacy Act.
Results in Brief
This investigation was initiated based on an Office of Inspector General (OIG) hotline complaint
by an individual who alleged that Kevin Brandt, Superintendent, Ohio Canal National Historical Park
(C&O NHP), National Park Service (NPS), Hagerstown, MD, improperly allowed Washington Redskins
owner, Daniel Snyder, to cut native trees on NPS land held in a scenic easement.
Our investigation revealed that NPS did not follow its own policies and procedures regarding the
process by which a property owner on an NPS scenic easement can cut vegetation above the allowable
limit. Our investigation determined that Superintendent Brandt, NPS National Capital Region officials,
and C&O NHP employees failed to initiate an environmental assessment, required by the NPS Directors
Handbook, when instituting changes to an easement agreement.
NPS, while granting Mr. Snyder exclusions through a Special Use Permit (SUP) to cut vegetation
above the allowable limit, did not complete the paperwork necessary to detail the reasons for granting the
exclusions as required by the NPS Directors Handbook.
Our investigation determined that P. Daniel Smith, former Special Assistant to the NPS Director,
unduly influenced the decision to grant Snyder permission to cut the vegetation on the easement by
inserting himself into the process through personal communications with Mr. Snyder, his representatives,
and C&O NHP officials. Smith asserted, in two interviews with investigators, that he became involved in
the tree-cutting issue at the request of NPS Director Fran Mainella. Mainella and several other witnesses
denied Smiths assertion.
This investigation was declined for prosecution by the United States Attorneys Office,
Washington, DC.
Background
In the early 1970s, NPS acquired 194 scenic easements at C&O NHP consisting of 1349 acres of
federal land and land interests within the park. These easements were acquired to provide protective
buffers, to limit development, to provide a natural view-shed and visual protections, and to better utilize
NPS land acquisition funds.
Over several decades since the easements were acquired, NPS and park staffs have been consistent
in their interpretation of scenic easement terms and conditions in response to landowner questions and
requests. As of the summer of 2004, no modifications had ever been made to the terms and conditions of
the 194 scenic easements along the C&O NHP. Any allowance for, or exceptions to, scenic easement
terms and conditions can only be made by modifying scenic easements terms through land protection
strategies, including memorialization through recordable documentation or by exceptions granted by the
Secretary of the Interior or designate.
In recent years, due to the Washington Metro area land values skyrocketing and increased
subdivision development, property owners subject to the scenic easements terms and conditions have
subsequently made an increased number of requests to cut on the land to improve their view of the
Potomac River.

3
The scenic easement involved in this investigation was originally acquired from a couple on
October 1, 1974. Daniel Snyder is an assignee to this easement, as a result of his purchase of the property
in 2001, which restricts certain activities over a described area of his property to protect resource and
aesthetic values.
In correspondence dated October 19, 2001, NPS was informed that Mr. Snyder was planning to
immediately remove all vegetation 6 inches diameter breast height (dbh) and under, prune trees within the
scenic easement and proposed to alter the height of his main house by adding a ballroom (Montgomery
County through a zoning ordinance, and NPS through the scenic easement agreement had to agree on the
proposed roofline/building elevation changes). This correspondence initiated a 3-year, on again, off
again, negotiation process between Snyder and NPS, culminating in Snyder cutting all of the vegetation in
a part of the scenic easement area on his property in the summer and fall of 2004.
Details of Investigation
The hotline caller alleged that Kevin Brandt, Superintendent of the C&O Canal NHP, allowed
Washington Redskins owner Daniel Snyder to cut native trees on NPS lands held in a scenic easement, in
violation of law and NPS policy.
According to the hotline complaint to the Department of the Interior (DOI) OIG, Daniel Snyder
allegedly contacted the Secretary of the Interior (Secretary) and offered to make several hundreds of
thousands of dollars available for NPS projects in exchange for allowing him to remove trees on the NPS
scenic easement land located on Snyders property. The complainant alleged that the tree removal was
conducted to improve and provide an unobstructed view of the Potomac River from Snyders residence.
The complainant stated that the Secretary allegedly notified the NPS Director, who in turn notified the
NCR Regional Director, who then notified Brandt, and finally, Brandt directed the C&O NHP Lands
Coordinator to negotiate the deal.
According to the complainant, NPS has had a policy of no compromise regarding view-shed
improvement. The complainant stated that the easement agreement allowed Snyder to cut trees under 6
inches dbh and remove diseased or dead trees for reasons of safety. The complainant said that Snyders
main issue was the scenic improvement of the property (an unobstructed view of the river from his
residence). The complainant also said the primary issue in the past for NPS was land encroachment by
landowners and its impact on park resources (personal gain versus detriment of park resources).
The complainant advised that NPS received a neighbor complaint in June 2004 that Snyder was
cutting small trees on the easement. The complainant stated that NPS verified that the cuttings were
legal (tree cutting below the 6-inch-dbh regulation) within the easement agreement.
The complainant related that Brandt had been negotiating with Snyders attorneys regarding a new
easement agreement that would allow Snyder to cut all non-native tree species, and underbrush, and
remove diseased, dead, injured or hazardous trees from the easement. Snyder would replace the trees
with native species and be allowed to keep the tree height cropped to facilitate an unobstructed view of
the river from his residence.
The complainant commented that this proposed agreement would be inconsistent with previous
NPS policy and fail to maintain the protective buffer between landowner properties and the river. The
complainant said Brandt was well aware of Snyders previous efforts to forge a new easement agreement,

4
as he was the assistant superintendent for 8 years at the C&O NHP prior to becoming superintendent in
early 2004. The complainant stated that Brandt did not have the authority to negotiate a new easement
agreement and land exchange involving park resources with Snyder. The complainant cited Chapter 1,
Section 4.7 of the NPS Management Policies Manual that states, Impairment of park resources is not
permissible under the law, unless directly and specifically authorized by Congress.
According to the complainant, the C&O NHP Lands Coordinator was the drafter of the proposed
new easement language regarding Snyder. The complainant advised that Brandt charged the Lands
Coordinator to craft the best deal possible for NPS regarding a new easement agreement. The
complainant stated that the Lands Coordinator said he felt the superintendent had reversed previous NPS
policy regarding the handling of scenic easements.
The complainant advised that when Snyder completed the first cut in early summer 2004, the
easement negotiations accelerated and, as the complainant observed, Brandt entered into a policy change
by agreeing to allow Snyder to cut trees over 6 inches dbh and into a trade-off of park resources through a
land exchange agreement.
The complainant advised that NPS does not have exclusive legal rights regarding the scenic
easement and that Montgomery County, MD, officials are investigating Snyder for violating the county
forest conservation law.
NPS Departure from Previous Policies and Procedures
The National Environmental Policy Act (NEPA) was passed by Congress in 1969 and took effect
on January 1, 1970. This legislation established this country's environmental policies, including the goal
of achieving productive harmony between human beings and the physical environment for present and
future generations. It provided the tools to carry out these goals by mandating that every federal agency
prepare an in-depth study of the impacts of major federal actions having a significant effect on the
environment and alternatives to those actions, and requiring that each agency make that information an
integral part of its decisions. NEPA also requires that agencies make a diligent effort to involve the
interested and affected public before they make decisions affecting the environment.
The NPS Directors Handbook, Order Number 12 (DO-12), derives in whole or in part from the
Interior NEPA guidelines. The processes described in the handbook are binding on all NPS personnel.
Under the terms of the National Parks Omnibus Management Act of 1998, the Secretary shall take such
measures as are necessary to assure the full and proper utilization of the results of scientific study for park
management decisions. In each case in which an action undertaken by the National Park Service may
cause a significant adverse effect on a park resource, the administrative record shall reflect the manner in
which unit resource studies have been considered. The development of alternatives, analysis of impacts,
and incorporation of the best available information, coupled with identification of environmentally
preferable courses of action as called for in this handbook, are one set of steps required in meeting this
obligation to the public.
NEPA requires two elements to be in place to achieve its stated intent. One is the requirement that
all agencies make a careful, complete, and analytic study of the impacts of any proposal that has the
potential to affect the environment, and alternatives to that proposal, well before any decisions are made.
The other is the mandate that agencies be diligent in involving any interested or affected members of the
public in the NEPA process.

5
Key features of the analysis are made available to the public in one of three types of NEPA
documents, depending on the degree of impact to the environment and the process outlined in DO-12,
Chapter 2:
1. Generally, if the proposal clearly has no potential for measurable environmental
impact, it is categorically excluded (DO-12, Chapter 3) and a short 1- or 2- page
notice is prepared (category exclusion form).
2. If it has the potential for significant environmental impact, an environmental
impact statement (EIS) is required if the proposed action would have a
measurable impact on the environment.
3. If it is unclear whether the action has the potential for a significant impact, an
environmental assessment (EA) is the appropriate document to prepare (DO-12,
Chapter 5). If the EA shows the action may have a significant effect, an EIS is
also required.
As of the summer of 2004, there had not been any modifications of the scenic easements along the
C&O NHP. NPS and C&O NHP officials circumvented the NEPA process by citing category exclusions
in DO-12, Chapter 3. NPS failed, however, to document its contention that there was no potential for
measurable environmental impact by not filing a category exclusion form. The form requires a brief
description and identification of the category used in excluding the action from further NEPA analysis.
The Associate Regional Director for the National Capital Region, NPS, pointed out that in 1971,
he wrote the original scenic easement agreements with local landowners along the C&O Canal for NPS.
He felt that he was nave in allowing vegetation cuts of anything under 6 inches dbh into the original
agreements and would change it if he could. He related that NPS wanted to do a land exchange to resolve
Snyders tree-cutting issue, which is a two-step process. The first step is the exchange agreement (signed-
off by Snyder and NPS in October 2004); the second step is to get a permit issued, which in Snyders case
happened 2 weeks later (November 2004). This type of land agreement is an exchange of land or interests
of real property between the United States and an owner of nonfederal land within a unit of the National
Park System.
According to the C&O NHP Lands Coordinator, he wrote and assisted in negotiating the land
exchange agreement between NPS, Daniel Snyder, and his attorneys. The Lands Coordinator also wrote
the SUP authorizing Snyder to cut trees on the scenic easement above 6 inches dbh in November 2004,
and to cut and clear non-native and native trees that were diseased, dead, injured, or hazardous. The Lands
Coordinator informed investigators that everything he wrote was reviewed and approved by an Attorney-
Advisor in the Office of the Solicitor.
The C&O NHP Lands Coordinator advised that Snyders attorneys gave repeated assurances to
him that they were in compliance with Montgomery County, MD, laws governing the cutting of
vegetation and trees on scenic easements. The Lands Coordinator took in good faith what Snyders
attorneys were telling him regarding approvals by Montgomery County and did not verify with the county
that Snyder had secured the necessary approvals to proceed with the proposed cutting.
The C&O NHP Lands Coordinator advised that Snyder had been negotiating with NPS for several
years to allow him to cut the vegetation on the scenic easement. The Lands Coordinator stated that he met

6
with Snyder in April 2004 and discussed a proposed land exchange agreement, which would take up to a
year to complete. He commented that Snyder was not happy with that timetable.
According to the Lands Coordinator, he consulted with NPS regional horticulturist and reviewed
all areas of possible concern for resource impact. He stated that the agreement underwent legal review.
However, he admitted that NPS did not follow the document procedure set forth in the NPS Directors
Handbook, DO-12, Chapter 3, Category Exclusions. The Lands Coordinator advised that the park did
not produce a category exclusion form or an environmental screening form, both required if using
exclusions under section 3.4, which the park cited on the Snyder Special Use Permit. These forms are
part of an internal scoping process and apply if section 3.4 exclusions are used.
The NPS Chief Horticulturist, in a memorandum dated July 8, 2004, commented that after the
June 2004 removal of the 6-inch dbh and under vegetation on the Snyder easement, the visual protection
and natural functioning of the plant community were severely compromised and increased the potential
for exotic invasion and erosion. The NPS Chief Horticulturist further observed that the 6-inch dbh or less
vegetation may result in a change in topography or disturbance of natural physical features that is
prohibited in the terms and conditions of the easement.
The NPS Chief Horticulturist estimated that in excess of 50 exotic trees over 6 inches dbh within
the easement were proposed for removal. He cautioned that even though the trees are recognized as
invasive exotics by NPS, they contribute to the visual protection desired in acquiring the scenic
easement. He said that unfortunately, the screening effect provided by the exotics has become even
greater as a consequence of the extensive vegetation removal recently conducted by the owner (Snyder).
Superintendent Kevin Brandt advised that he had been the Deputy Superintendent at the C&O
NHP for 8 years under the former Superintendent of the C&O NHP. Brandt became the acting
superintendent in September 2003, following the retirement of the former Superintendent. While the
deputy, Brandt said the former Superintendent did not involve him in the Snyder negotiations. After a lull
in the negotiations between Snyder and NPS from 2002 through 2003, Brandt stated discussions were
resumed in the late winter of 2004. Brandt advised that he sent a letter to Snyders attorney in February
2004 regarding the easement and reiterated the existing NPS policy of no cutting.
Brandt commented that two employees from the National Trails Land Office, NPS, Martinsburg,
WV, had been in contact with Snyders representatives before Brandts February 2004 letter was sent
regarding an offer setting conditions for a land exchange agreement. Brandt related that the C&O NHP
Lands Coordinator met with Snyder to discuss the land exchange in April 2004 and told Snyder that the
timeframe for completing such an exchange would be approximately one year.
Brandt related that he met with the C&O NHP Lands Coordinator and Snyder at Snyders
residence in June 2004. Brandt stated that Snyders Attorney was also present and told him they had
Montgomery County approval for further clearing of the remaining vegetation. Brandt admitted that he
was aware that the county had a say in the decision to cut and remove vegetation from the Snyder
property but did not follow up with Maryland officials. Brandt claimed the responsibility lay with the
Snyder people to satisfy Maryland authorities regarding approvals.
Brandt admitted that he did not follow NPS administrative policy in producing the necessary
paperwork to document the creation of a new easement agreement and the issuance of the SUP for the
Snyder property. Brandt felt that the category exclusions cited in the SUP dealt with resource

7
management and did not require an EA or EIS. Brandt acknowledged that this is the first permit issued
for cutting on a scenic easement and was advised by the Associate Regional Director for the National
Capital Region, NPS, that these types of land exchanges do not require an EA. Brandt also knew that he
should have provided a justification statement for the proposed land exchange indicating that all exchange
criteria have been considered as directed by the NPS guidelines on Exchanges, Part XV, Chapter 3,
section 3.2.
Brandt claimed that in December 2004, he briefed NPS Director Fran Mainella and the Regional
Director for the National Capital Region after Snyder cut the remaining exotic and native trees on the
easement in November 2004. Brandt stated there were subsequent conversations between himself and
Director Mainella regarding Snyder.
According to the Regional Director for the National Capital Region, category exclusions must be
signed off on by the regional director and this was not done. He pointed out that removing exotics are the
heart of NPS mission and that their removal is secondary to our nature. He offered this not as an
excuse, but as an explanation for why the required paperwork and procedures for this type of exchange
were not followed.
Brandt told the Regional Director for the National Capital Region that Snyders attorneys told him
that Montgomery County had given Snyder approval for clearing the easement, but that there was no
follow-up with Montgomery County to see if this was true. The Regional Director admitted that the
follow-up should have been done by Brandt instead of taking the word of Snyders attorneys. The
Regional Director said that he will decide what action to take after learning what action Montgomery
County takes and admitted that maybe they should re-look the agreement with Snyder.
According to the NPS Associate Regional Director for the National Capital Region, NPS used
categorical exclusions derived from the NPS Directors Handbook for the permit and stipulated that
Snyder had to pay for an EA. The Associate Regional Director advised Superintendent Brandt that an EA
was not needed initially because the growth to be cut on Snyders property was primarily exotic trees.
AGENTS NOTE: It was pointed out to the NPS Associate Regional Director for the National Capital
Region that the NPS Directors Handbook advises that an EA needs to be done if two categorical
exceptions are given and, in this case, three categorical exceptions were given. The Associate Regional
Director agreed that this was correct and said that he based his opinion on practical experience. He
stated that he sensed no disagreement from either side in moving this along.
According to Brandt, the NPS Associate Regional Director for the National Capital Region told
him that an SUP did not need an EA but that the land exchange did require one, and he acted using the
Associate Regional Directors guidance. The land exchange agreement stipulated, An EA was to be
conducted and paid by Snyder as part of the land exchange agreement with NPS [Page 3, #6]. The
agreement did not specify when the EA was to be conducted, before Snyder cut, or after. There is no
mention in the SUP regarding an EA.
However, the NPS Associate Regional Directors comments are contradicted by the Chief
Horticulturists memorandum dated July 8, 2004, regarding the Snyder scenic easement, in which the
Chief Horticulturist states, input (for the memo) was received from [the Chief, Natural Resources and
Science], [the NPS Associate Regional Director for the National Capital Region], [the Chief, Land
Resources Program] and [the C&O NHP Lands Coordinator]. The NPS team made observations,

8
commented, and made recommendations to Superintendent Brandt regarding the Snyder easement in the
summer of 2004.
In the memo, the NPS team recommended:
the area cleared within the addressed 200-foot zone of the easement must remain natural
to provide seamless continuity with the surrounding vegetation to achieve the screening
intent of the easement. It is our professional determination that the best approach to restore
the site and achieve this intent within the 200-foot easement would be to allow natural
succession to occur by permitting all native vegetation to grow to its full potential and to
remove exotic species as they compete with native plants. Deliberate planting in this area
will only add to the recent disturbance and increase the potential for erosion and exotic
plant invasion. There is sufficient seed source in the surrounding natural areas to sustain
the native plant community without additional planting.
AGENTS NOTE: Snyder planted over 600 seedlings after the November 2004 cut of vegetation 6-inch
dbh and over. Snyder, in addition to cutting all exotic species within the 200-foot easement, cut all of the
native species, whether healthy, diseased, injured or considered hazardous.
The NPS team also recommended a Clarifying Attachment to the existing easement that clearly
defines the terms and conditions under which the easement will be maintained. The attachment should be
in the form of a legal document to be signed by both parties (Snyder/NPS) and recorded in the County
Land Records. In the memo, the Chief Horticulturist used the phrase in the timeframe the owner has
requested. The C&O NHP Lands Coordinator had also commented that after his April 2004 meeting
with Snyder, Snyder had expressed unhappiness regarding the timetable for the completion of a land
exchange agreement.
An Attorney-Advisor has been with the Solicitors office in DOI for 10 years and has worked
extensively with NPS on land exchanges within the last 6 years. The Attorney-Advisor normally reviews
land exchanges to check the language, definitions used, and statutes cited for proper use. The Attorney-
Advisor does not recall ever working on a scenic easement issue.
The Attorney-Advisor said they reviewed the Snyder land exchange agreement and the SUP in
October 2004 and found them to be in legal order. The Attorney-Advisor told either the NPS Associate
Regional Director for the National Capital Region or the C&O NHP Lands Coordinator that they should
consider adding more exceptions to the SUP other than the one originally cited.
The Attorney-Advisor described Superintendent Brandt as being anxious regarding Snyders
tree-cutting issue. The Attorney-Advisor had met with Brandt and the C&O NHP Lands Coordinator on
several occasions relating to the easement documents. The Attorney-Advisor said the Snyder land
exchange was a legally appropriate document and defensible. The Attorney-Advisor added that the SUP
was unusual in regard to other land exchange agreements and that they do not see too many of these
permit types.
The SUP also required the Snyders to obtain a Letter of Credit (LOC) from Bank of America for
$100,000 in lieu of a performance bond to ensure the work was completed according to the terms of the
SUP. LOCs are routinely used in commercial transactions. The Snyder LOC is a particular type of LOC
called a standby LOC because its purpose is to protect NPS from another partys unsatisfactory

9
performance or inability to perform. In addition, the SUP incorporated NPS conditions. These provisions
require the Snyders to comply with all applicable laws, regulations, and permitting requirements and to
ensure that they do not knowingly present false information. The NPS may present and demand payment
of the LOC if the Snyders failed to comply with the terms of the SUP.
An Attorney from the Maryland-National Capital Park and Planning Commission (M-NCPPC),
Silver Spring, MD, said that Snyder initially requested an exemption from Montgomery County to add a
ballroom to his residence in 2001, thus altering the roofline of the main house (hereafter referred to as the
roofline/building elevation issue). The county ordinance provides for a roof height of 50 feet, exclusive
of chimneys. In early 2002, this issue became resolved, and Snyder added the ballroom to the main
house. According to the Attorney, Snyder provided a Declaration of Intent, as defined in Chapter 23A of
the Montgomery County Code, in which he said that he would not make any other alterations to the
residence for 5 years.
The Attorney from the Maryland-National Capital Park and Planning Commission pointed out that
officials in Montgomery County became aware of the more than 40,000 square feet of trees that Snyder
cut down in November 2004 after neighbors and other county residents wrote letters to M-NCPPC
complaining about the property Snyder had cleared. Snyder was cited by Montgomery County for
violating county code in December 2004, and fined $1,000.
The M-NCPPC Attorney said, to my knowledge no one [from NPS] contacted this agency for
either understory or overstory clearing at Snyders residence. According to Montgomery code,
Snyder and others have 5,000 square feet of understory exemption. The Attorney pointed out that
Chapter 22A-4 of their code requires a permit to cut more than 5,000 square feet of land.
The Attorney pointed out that Montgomery County uses the terms invasives or non-native
species instead of the term exotics used by NPS for unwanted vegetation. The county code allows the
clearing or removal of non-native species by hand, one plant at a time, no machines. The Attorney said
that no clear cut, as Snyder did, is allowed because the canal involves steep slopes and clear cutting
results in erosion.
The Attorney advised that Snyder and M-NCPPC signed a settlement agreement on August 8,
2005. The agreement requires Snyder to implement a restoration planting plan approved by the
Commission within 90 days after execution of the agreement. The plan includes reforestation of 1.3 acres
of cleared area, enhanced planting outside the cleared area, purchasing the equivalent of three acres of
land to be deposited in a forest conservation bank (minimum to be spent-$37,000), permanent protection
of existing forest, and posting a $45,000 bond for 2 years of maintenance costs.
M-NCPPC provided an incomplete inventory of native species trees cleared by Snyder in the
affected easement area. The inventory was incomplete due to GPS equipment failure. No value was
placed on each tree by M-NCPPC. Also, the condition of each native tree cut could not be determined.
According to M-NCPPC, a total of 34 native species trees over 6-inches dbh were cut by Snyder on the
easement.
The Attorney said that they have been in contact with NPS to ensure that there is no future lack of
communication between NPS and the county in matters affecting easement areas. They are working out a
system with NPS to prevent this type of lapse in the future.

10
According to NPS Director Fran Mainella, in the future, and in response to the controversy
surrounding the Snyder tree-cutting issue, she agreed to push her subordinates, mainly park
Superintendents, to follow Directors Order 75A, which states that NPS should reach out to their various
local communities (such as Montgomery County) and establish contacts. Mainella felt that this would
prevent the Superintendents from operating in a vacuum.
An employee in the NPS Office of Congressional and Legislative Affairs (OCLA) advised that he
became aware of the Daniel Snyder tree-cutting issue in January 2005. He recalled that a Congressman
had inquired as to what happened regarding the Snyder tree cutting. He related that in response to the
Congressmans inquiry, he scheduled a meeting with Superintendent Brandt on January 12, 2005, to be
briefed on the tree-cutting issue. He mentioned that a Legislative Specialist joined the meeting with
Brandt.
The OCLA employee described Brandts briefing as an overview of the land exchange agreement,
a discussion of the media fallout, before and after photographs of the easement trees, the new plantings on
Snyders property, why the agreement was reasonable and the criticism of NPS from neighbors and
interested parties. The employee recalled that Brandt raised the issue of invasive species that needed to be
removed from Snyders property. The employee thought he may have taken Brandt up to Capitol Hill to
brief the Staff Director of the House of Representatives Sub-Committee on Parks.
P. Daniel Smiths Influence on Snyders Land Exchange
P. (Paul) Daniel Smith (Danny or Dan Smith) had been employed by NPS for 3 years as the
Special Assistant to NPS Director Mainella before he was named Superintendent of the Colonial National
Historical Park on December 1, 2004. Smith handled Special Projects for the NPS Director characterized
by intense interest from the public, special interest groups, Cabinet level officials and Congress. Smith
exercised full delegated management authority for project planning and implementation. Smith served as
the Directors principal representative in managing activities associated with special projects.
Smith had previously been involved with public/private citizens and NPS issues. A Park Ranger
at the George Washington Memorial Parkway advised that he had met twice with Smith regarding issues
involving congressmen and private citizens. The first involved a GW Parkway Superintendent asking him
to meet with Smith in the area of the Iwo Jima Memorial in 2002. The Park Ranger said he met Smith
and a Member of Congress from Florida. According to the Park Ranger, the Member of Congress was
condo shopping with Smiths assistance. The Park Ranger commented that the Member of Congress
spoke to him regarding trees along the GW Parkway that could possibly block a view from a condo he
was considering purchasing. The Park Ranger said the Member of Congress asked if the trees could be
cut.
The second encounter with Smith occurred during 2003 to 2004 and involved a property owner
whose driveway was encroaching into the GW Memorial Parkway. The Park Ranger attempted to resolve
the issue; however, the owner wrote a letter to his Senator, complaining about the Park Ranger and NPS.
The Park Ranger advised that P. Daniel Smith became involved and ordered the Park Ranger to meet with
him at DOI. Smith told the Park Ranger to resolve the issue with a land exchange. The Park Ranger
recalled that he never spoke again to Smith. The Park Ranger felt that Smiths personal attention and high
level involvement with both incidents was odd.

11
The Park Ranger was asked by investigators whether he had knowledge regarding the Snyder tree-
cutting issue at the C&O NHP. He advised that he had contact with a few friends at the canal and was
told by them the issue was mishandled by NPS. The Park Rangers own opinion was that NPS changed
course in the Snyder case. He specified that NPS had always protected trees and vegetation with a no-cut
policy and in the Snyder case, for some reason, reversed that policy.
According to the C&O NHP Lands Coordinator, Smiths involvement with the Snyder easement
issue dated back to early 2002. The C&O NHP Lands Coordinator provided investigators with a memo
from his work calendar dated January 28, 2002. He wrote:
9:30 am. Call from Mr. Dan Smith, Special Assistant to the Director. Mr. Smith wanted to
know the status of the Snyder easement request and correspondence. He asked if
cutting/building issues had been resolved. I said the building issue was solved but that we
were trying to mitigate Mr. Snyders intention to cut all trees 6 inches dbh and under. Mr.
Smith asked if we allowed mitigation donations. I said that mitigation would be based on
equal value exchange of interest based on fair market appraisal.
Smith advised that he does not recall speaking to the C&O NHP Lands Coordinator regarding the
tree-cutting issue in January 2002, only the roofline/building elevation issue, nor did he recall speaking to
the C&O NHP Lands Coordinator regarding an offer of $25,000 from Daniel Snyder to NPS to mitigate
tree-cutting and roofline/building elevation issues.
AGENTS NOTE: In a letter from Snyders land-use Attorney to the former Superintendent of the C&O
NHP, dated January 8, 2002, Snyders Attorney proposed that Snyder would agree to mitigation in the
form of a cash contribution in the amount of $25,000 to be used for a flood fund that was established for
the C&O Canal or another fund of the Parks choosing previously mentioned by the former
Superintendent. In a subsequent letter to Snyders Attorney, dated January 28, 2002, the former
Superintendent wrote, We regretfully cannot accept Mr. Snyders generous offer of a $25,000 cash
contribution as mitigation for scenic easement variance requests.
The C&O NHP Lands Coordinator related that he received a telephone call from Smith after his
(the C&O NHP Lands Coordinators) April 2004 meeting with Snyder. Smith told the C&O NHP Lands
Coordinator that he had received a call from Snyders Attorney and that Snyder was not happy with the
pace of the negotiations with NPS concerning the scenic easement. Smith continued and stated that
Snyder wanted to address the issue of exotics on the easement. Snyder wanted to cut the exotics over 6
inches dbh on the easement. Smith opined to the C&O NHP Lands Coordinator that NPS was in the
business of eradicating exotic species and that Snyder wanted to do the same. The C&O NHP Lands
Coordinator commented that the tone from Smith was lets get this done.
The C&O NHP Lands Coordinator admitted that after his conversation with Smith, he felt
pressure to secure an agreement with Snyder. He related that he met with Smith at least twice after the
call, once at Snyders residence in June 2004 and another time on the C&O Canal towpath below
Snyders residence.
Superintendent Brandt advised that shortly after the C&O NHP Lands Coordinators April 2004
meeting with Snyder, he had a telephone conversation with Smith. Brandt recalled that Smith raised the
issue of exotic trees, asked if NPS was removing exotics elsewhere, and asked why NPS would not

12
discuss their removal in regard to the Snyder property. Brandt did not view the call from Smith as
unusual but admitted that this was the first time he had received such a call.
AGENTS NOTE: Brandt was interviewed a second time by investigators approximately one month after
his initial interview. The following statements by Brandt are in contrast to his previous testimony.
Brandt, in his second interview, said that in retrospect, P. Daniel Smith came to be involved
differently in the Snyder tree-cutting issue than he initially explained to investigators. Brandt advised that
Smiths involvement had a substantial impact on how he made his decisions concerning the Snyder tree-
cutting issue.
Since Smith worked directly for the NPS Director, Brandt said, In my mind there is no internal
reason to raise the issue to his [Smiths] level that I am aware of. Brandt felt the tree-cutting issue
should have been decided solely at the Superintendents level, not from NPS Headquarters. According to
Brandt, after he briefed Smith over the phone in late summer 2004, Brandt had no further contact with
Smith about Snyder.
When Brandt was asked if Smiths call had any impact on him, Brandt responded, Im sure it
influenced me. Brandt believed that Smiths presence and involvement affected his decisions regarding
the Snyder negotiations. Brandt said he was told by unnamed persons at NPS Headquarters that Danny
Smith was going down the hall saying, I cant believe that they wont let them cut exotics, when
referring to the Snyder tree-cutting issue. In order to place what occurred in context, Brandt pointed out
that he was a new superintendent and he wanted to be considered a team player, which added to the
impact of Smiths influence on him. He had never talked with Smith before and felt that a call from
anybody in the NPS Directors office was important. Brandt felt that Smith was representing the NPS
Director on the tree-cutting issue, resulting in Brandt feeling pressure to meet what he believed were
Smiths expectations. Brandt also pointed out that, if Smith had not been involved, he would not have felt
the need to get personally involved himself. Brandt, in retrospect, said that he would have taken his
time, especially concerning the land exchange, if not for Smiths continued involvement.
According to Brandt, he did not feel any influence directly from the NPS Director. In fact, Brandt
said that the only thing he said to the Director was, Weve been working with Dan Smith on the Snyder
thing.
The Chief of Interpretation, C&O NHP, advised that he was the Acting Superintendent for the
C&O NHP when he received a telephone call on June 2, 2004, from P. Daniel Smith regarding the Snyder
tree-cutting issue. The Chief of Interpretation related that Smith told him that Daniel Snyder had called
the Secretary of the Interiors office and the call eventually reached him. Smith told the Chief of
Interpretation that Snyder was unhappy with the delay for a solution to his tree-cutting problem. Smith
informed the Chief of Interpretation that he told Snyder to go ahead and cut the 6-inch dbh and under
vegetation on his property.
The Chief of Interpretation recalls having the impression from Smith that Secretary Norton or
Director Mainella wanted the Snyder tree-cutting issue resolved. The Chief of Interpretation commented
that he does not recall Smiths exact words that caused him (the Chief of Interpretation) to form this
impression. He said he felt that Smith was pressuring the C&O NHP officials to resolve the issue in favor
of Snyder.

13
According to P. Daniel Smith, he became involved with the Snyder tree-cutting issue in the late
summer of 2004. Smith advised that he received a telephone call from an Attorney for the Washington
Redskins. Smith stated that he had previously worked with Snyder attorneys to resolve the
roofline/building elevation issue at the Snyder residence in 2002. Smith recalls speaking on several
occasions with the Redskins Attorney prior to their first meeting. Smith related that he had broad
discretion to resolve the easement issue with Snyder. Smith did not elaborate on who might have given
him that discretion. Smith said that in the spring of 2004, the Redskins Attorney invited him to lunch at
the Snyder residence to discuss the tree-cutting issue. Smith related that this lunch occurred before
Snyder cut the understory on his property in June 2004.
AGENTS NOTE: Smiths recollection of pertinent dates relating to the tree-cutting issue changed as
the interview progressed.
Smith claimed to follow up on the Snyder lunch issues with the appropriate C&O NHP staff.
Smith stated that he walked Snyders property and the towpath below the scenic easement. Smiths
impression was that Snyder was frustrated with the lack of progress over the tree-cutting issue with
NPS. Smith remembered speaking with the Redskins Attorney several weeks after the meeting at
Snyders residence and advised him to work through Superintendent Brandt. After the phone call with the
Redskins Attorney, Smith said he was not involved with the issue again.
Smith related that he does not recall speaking to Superintendent Brandt over the phone regarding
the technical aspects of the Snyder tree-cutting issue; however, he said he phoned the C&O NHP Lands
Coordinator several times to discuss technical issues. Smith admitted that he may have spoken to Brandt
over the phone to arrange meetings of issue principals in the spring of 2004; in contrast, Brandt stated that
he fielded several telephone calls from Smith on the Snyder issue from April 2004 through the fall of
2004.
According to Smith, he thinks he became aware of both the Snyder roofline/building elevation and
tree-cutting issues after someone mentioned them to Director Mainella during a Redskins football game.
Smith did not recall what month or year this alleged conversation took place. Smith advised that he was
positive that no one else in DOI or on Capitol Hill was involved regarding the Snyder tree-cutting issue.
Smith denied exerting any pressure on Superintendent Brandt or anyone at the C&O NHP on this issue.
According to Director Mainella, she does not know how Smith became involved with the Snyder
tree-cutting issue. Mainella recalled that Smith had been previously involved in a C&O issue when
complaints came in regarding the former Superintendent not getting along with a few C&O property
owners. Mainella believes Smith became involved at the request of a Congressman. According to Smith,
he did not speak with a Congressman regarding the Snyder tree-cutting issue.
Mainella was advised by investigators that Smith had stated in his interview that someone had
approached Mainella at a Redskins football game and asked her to assist in Snyders tree-cutting and
roofline/building elevation issues with NPS. Mainella stated that Smiths version was not true.
Smith stated that he originally dealt with the Snyder land-use Attorney concerning the
roofline/building elevation issue, which Smith believes occurred in the fall of 2001 or 2002; he could not
be certain. However, Smith reiterated his prior claim that NPS Director Mainella met someone at a
Redskins football game and she told this person to call Smith to resolve Snyder's tree-cutting issue. Smith
states that Snyders land-use Attorney called him shortly thereafter and made an appointment regarding

14
the tree-cutting issue. Smith did not recall when this issue first presented itself. Smith believed he had an
initial meeting with Snyders land-use Attorney in October or November 2001, during football season.
Snyders land-use Attorney recalled contacting Smith directly regarding the tree-cutting issue. He
did not remember how he obtained Smiths name and number but said he met with Smith at DOI
sometime in the fall of 2001. The Attorney stated that he brought a copy of the easement agreement to
the meeting. According to the Attorney, mitigation issues did not come up in the discussion, and he did
not bring any blueprints of Snyders residence to the meeting. He also does not remember discussing
Snyders roofline/building elevation issue at the meeting. The Attorney commented that Smith promised
to send the agreement to the DOI Solicitors office and gave him the name of the former C&O NHP
Superintendent. The Attorney advised this was his only contact with Smith concerning Snyders tree-
cutting issue and, thereafter, he dealt solely with the former C&O NHP Superintendent.
Smith stated that he never briefed Director Mainella on the Snyder tree-cutting issue. He
reiterated that someone had mentioned Snyders problems to Director Mainella at a Redskins-Giants
football game in 2001 or 2002. Smith affirmed his earlier assertion that through that conversation,
Mainella asked him to look into Daniel Snyder's proposals and concerns. Smith advised this is how he
became involved with Daniel Snyder's tree-cutting and roofline/building elevation issues.
Mainella was advised by investigators of Smiths second interview regarding his involvement in
Snyders tree-cutting issue. Mainella was told that Smith maintained that he became involved with
Snyders problems after Mainella had attended a Redskins football game and was asked by someone to
assist in Snyders tree problem with NPS and that Mainella asked Smith to look into the tree-cutting issue.
Mainella reiterated her prior statement that Smith was mistaken in his recollection.
Mainella also reported that, after checking her schedule and speaking with her husband, she is
certain that she has only attended one football game in Washington, D.C. She claimed that she attended a
game in the fall of 2003 with her husband and several officials from the Bush administration. She had no
memory of speaking to anyone regarding Daniel Snyder or the C&O NHP during the game.
The NPS Deputy Director related that he never had been personally contacted by anyone from
inside or outside of DOI regarding the Snyder tree-cutting issue and was unable to explain how Smith had
become involved. The Deputy Director did confirm that if an issue involving the C&O NHP had been
presented to the NPS, it would have been passed along to Smith.
The Deputy Director was advised that Smith had told investigators that NPS Director Mainella
had spoken with someone at a football game regarding Snyders problems and had promised to have
someone look into Snyders tree-cutting issue. The Deputy Director said he had never heard such an
account and speculated that Smith was confused.
The Redskins Attorney advised that he became involved with the Snyder tree-cutting issue in early
2004, when he telephoned P. Daniel Smith and discussed a resolution to the problem. The Redskins
Attorney said he does not remember how he obtained Smiths number. He thought he got the number for
Smith from someone outside of government channels.
The Redskins Attorney recalled speaking to Smith on several occasions in the spring of 2004. He
remembered a meeting at Snyders residence in the summer of 2004 with Superintendent Brandt, the
C&O NHP Lands Coordinator, and Smith to discuss a resolution to the tree-cutting issue.

15
Smith claimed that the Redskins Attorney introduced the topic of invasive species by producing a
pamphlet authored by NPS on exotic vegetation removal. Smith responded that he did not know why
NPS was not concerned with removal of exotics. Smith recalled speaking to the Redskins Attorney
regarding the progress of the tree-cutting negotiations during the summer of 2004.
According to the Redskins Attorney, he did not recall NPS Director Mainella ever attending a
Redskins game as a guest of Mr. Snyder. Investigators related Smiths recollection that someone had
approached Mainella at a Redskins game regarding Snyders problems with cutting vegetation on his
property. The Redskins Attorney stated that he does not believe Smiths recollection to be plausible. The
Redskins Attorney did not recall speaking with any other NPS or DOI officials regarding the Snyder tree-
cutting issue. He believed that a wealthy friend of Snyders, with similar tree-cutting issues, referred
Smith to Snyder.
According to another Attorney for Daniel Snyder, he could not recall NPS Director Mainella ever
attending a Washington Redskins football game as a guest in Daniel Snyders private suite. The Attorney
checked the list of attendees for Snyders box for the past 4 years and Mainellas name did not appear on
the list.
As to the question of how Smith became involved in the Snyder tree-cutting issue, Snyders
Attorney surmised that Snyder had conversations with many people regarding the tree-cutting problem.
Through discussions with others, the Attorney assumed that the topic made its way to NPS and eventually
to Smith. The Attorney related that it was Smith who initially called Snyder and said he would handle the
matter. The Attorney stated that Smith later met Snyder and put him in touch with Superintendent Brandt.
Thereafter, the Redskins Attorney and Brandt worked together on a resolution.
Smith insisted that he never called Snyder or his attorneys first; they contacted him over the tree-
cutting issue. Smith said he took a telephone call from Snyder and the Redskins Attorney in the spring of
2004 asking him to resolve the impasse between NPS and Snyder. Smith did not recall speaking with the
other Snyder Attorney.
A Special Assistant to the NPS Director claimed that he was unaware that Snyder had ever
contacted NPS regarding construction or clearing trees along the C&O NHP until news articles appeared
in The Washington Post in 2004. He also could not explain how Smith had become involved. The
Special Assistant admitted that while it appeared to him that some DOI political or some congressional
member had asked Smith to handle Snyders tree-cutting issue, he had no direct knowledge of any such
call or conversation. He denied any knowledge or that he had ever heard that Secretary Norton, the
former Deputy Secretary, or any other DOI official was involved or tried to influence a decision by NPS
personnel. The Special Assistant was aware that a Congressman had been involved in previous issues
associated with the C&O NHP but was confident that the Congressman was not involved in this particular
issue.
The Special Assistant was advised that Smith had told investigators that NPS Director Mainella
had spoken with someone at a Redskins football game about Snyders problems and had promised to have
someone look into the issue. The Special Assistant denied that he had ever heard such an account and
expressed certainty that if he had ever heard such a story, he would remember it.

16
The Special Assistant confirmed that if an issue involving the C&O NHP had been presented to
NPS, it would have routinely been passed along to Smith. He claimed that the former C&O NHP
Superintendent could be very difficult to deal with and he was not surprised that Brandt had little or no
exposure to Snyders tree-cutting and roofline/building elevation issues while serving as the former
Superintendents deputy. The Special Assistant admitted that he knew Superintendent Brandt well and
considered him a good person, but unprepared to deal with Snyders attorneys.
NPS Director Mainella advised that Superintendent Brandt may have made some inexperienced
management decisions regarding Snyders tree-cutting issue if he was receiving communications from
Smith. Mainella reiterated that she did not direct Smith to become involved with Snyder.
Superintendent Brandt opined that in retrospect, if not for the involvement of Smith, he probably
would have done things differently regarding Snyder. Brandt said, I would have arrived at a different
decision.
The impact of the NPS and the C&O NHP decision to allow Snyder to cut all vegetation on the
scenic easement compromised their previous no-cut policy regarding easements and removed a visual
buffer between the visiting public and landowner in contradiction as to why the easement was purchased
originally. NPS also failed to follow the DO-12 NEPA analysis and documentation. NPS permitted the
influential intervention of P. Daniel Smith into the decision-making process through his position as a
Special Assistant to the NPS Director and minimized Superintendent Brandts authority to make an
independent judgment. NPS was also subjected to adverse media accounts regarding their business with
Snyder. Smith, over the course of two interviews with investigators, was less than candid in many of his
recollections of events regarding how he became involved with the Snyder tree-cutting issue.
In the summer of 2004, the NPS Chief Horticulturist had warned that the removal of the 6-inch
dbh and under vegetation on the Snyder easement severely compromised the visual protection and
natural functioning of the plant community and increased the potential for exotic invasion and erosion.
The Chief Horticulturists team also advised that deliberate planting (Snyders 600 saplings) in this area
would only add to the recent disturbance and increase the potential for erosion. His prediction has proven
true, as erosion is evident in ground level and aerial photographs taken of the Snyder residence since the
June and November 2004 vegetation cuts.
This investigation was presented to the Assistant United States Attorney for Washington, D.C., of
the Fraud and Public Corruption unit. It was declined for prosecution due to lack of prosecutorial merit.
Disposition
This investigation has been concluded and referred to NPS for appropriate action.

Exhibit 61
Parks Official Is Blamed In Snyder Tree
Cutting
Redskins Owner Wanted Better River View
By Tim Craig
Washington Post Staff Writer
Friday, May 19, 2006
A high-ranking National Park Service official improperly helped
Washington Redskins owner Daniel M. Snyder broker a deal to
cut down more than 130 trees on a hillside between his Potomac
estate and the C&O Canal, according toa report by the Interior
Department inspector general's office.
The 2004 decision should have been left to park biologists and
horticulturists, who had advised against the deal on federally protected land, and should have been opened to public
debate, the report says. After an eight-month investigation, the office concluded that P. Daniel Smith, then special
assistant to the director of the Park Service, intervened to help clear Snyder's view of the Potomac River.
The report does not accuse Snyder of doing anything improper when he got permission to clear 50,000 square feet
of mature trees and replace them with saplings. But it does suggest that he had access to top Park Service officials
that other citizens might not have had.
Smith pressured lower-level officials to approve a deal that disregarded federal environmental laws, harmed the
Chesapeake & Ohio Canal National Historical Park and left the agency vulnerable to charges of favoritism,
according to the unsigned report, a copy of which was obtained by The Washington Post.
Smith -- now superintendent of Colonial National Historical Park, which includes Historic Jamestowne and
Yorktown Battlefield -- said in an interview that he received a letter of reprimand last month for "overstepping his
discretion" but did "nothing tawdry."
"It was a legitimate request by a landowner who had a legitimate issue with the Park Service," Smith said.
Snyder issued a brief comment through a spokesman yesterday, saying he and his representatives "negotiated a fair
written agreement with the National Park Service. They didn't put pressure on anyone."
In previous interviews, Snyder's representatives said he was trying to rid his property of invasive species, such as
ailanthus and paulownia. He has said he spent about $100,000 to replace a once-tangled mess of trees, many of
which were nonnative species or diseased, with more than 600 native saplings that will boost the long-term viability
of the forest.
The Park Service's horticulturist, however, told the inspector general that clearing the area made it more likely that
nonnative, invasive species would eventually flourish on the hillside and cause erosion.
The report, to be made public today, says Smith "unduly influenced the decision" by "inserting himself into the
process through personal communications with Mr. Snyder, his representatives and C&O Canal officials." The
inspector general referred its findings to the U.S. attorney's office, which declined to prosecute, according to the
report.
Smith's job was to handle special projects for Fran P. Mainella, the Park Service director, including topics of
"intense interest from the public, special interest groups, Cabinet level officials and Congress," the report says.
Mainella declined to comment, but her office issued a statement saying it would not comment on Smith's role
because it was a personnel matter. The "outcome of what was done on the easement property will show it will best
benefit the C&O Canal National Historical Park and best benefit the visitor," the statement said.
After joining the Park Service in 2001, Smith said, he was assigned to troubleshoot important issues, many of
which came from members of Congress. "I had very broad discretion in all kinds of matters that came to the
department," he said.
Smith told investigators that Mainella asked him to help Snyder after she was approached by someone at a Redskins
game during the 2001-02 season, the report says. But Mainella, whom President Bush appointed in 2001, told the
inspector general's office that she never intervened on Snyder's behalf and that she does not remember discussing
the matter with Smith or attending a game that year, according to the report.
In an interview, Smith said investigators in their report misconstrued his statements about Mainella's role.
Smith said Mainella "was not involved about the trees." She had asked him to represent the Park Service on an
earlier, separate request from Snyder in 2001 to build a ballroom on the estate he bought that year from Queen
Noor, the widow of Jordan's King Hussein, for $10 million. Snyder needed Park Service approval to build the
ballroom because it increased the size of the estate on an easement the agency obtained on the property in 1974.
That request was approved.
The inspector general's office "got two things confused. They were two separate incidents that happened 2 1/2 years
apart," Smith said.
The inspector general's report says Smith's involvement with the tree removal issue dated to 2002, when Smith
called a lower-level park official to raise questions about that request.
In 2004, Kevin D. Brandt, superintendent of the C&O Canal park, negotiated a deal with Snyder allowing him to
cut the trees and replace them with more than 600 native trees, such as pines.
Snyder agreed to donate an additional portion of his property to the Park Service as well as to calculate the value of
his improved view. If the value of the enhanced view exceeded the value of what the Park Service gained, Snyder
was to donate the difference to the federal government.
The deal outraged environmentalists and some members of Congress, who wondered whether the Park Service was
in the business of selling views. After initially saying the trees were cut "by mistake," Brandt said last year that he
negotiated the deal with Snyder to improve the long-term vitality of the park through the removal of nonnative
species. In numerous interviews with The Post, Brandt said he never felt pressured into making the deal.
The Interior Department investigators said Brandt told them something different.
"I'm sure it influenced me," Brandt told investigators, adding that he assumed Smith was acting on behalf of
Mainella, according to the report. Brandt did not respond to a request for an interview through the Park Service's
public affairs office.
In the Reagan administration, Smith worked for the Department of the Interior, including as deputy assistant
secretary for fish, wildlife and parks. For part of the 1990s, he worked on Capitol Hill for the House subcommittee
on national parks and public lands.
Snyder had been trying for years to get permission to remove the trees behind his house, including an offer in 2002
to donate $25,000 to the Park Service if the trees could be cut, according to government documents. The previous
superintendent of the park, Douglas D. Faris, denied the request.
In spring 2004, Snyder renewed his request for permission to cut the trees. Smith said Snyder and his attorneys
called him and requested a meeting, which was held over lunch at the Snyder residence.
At the lunch, Snyder said he needed help expediting his request because a geothermal heating system was being
installed in his back yard, Smith told The Post. Once it was in place, Snyder said, he wouldn't be able to place
heavy equipment in his back yard, according to Smith's recollection of the meeting.
About two months after the lunch, Smith said, he took about a half-dozen officials -- including Brandt and staffers
from the Park Service's regional office -- to Snyder's house. "I said, 'Mr. Snyder, these are the people you will have
to work with to resolve the issue,' and I never touched the issue again," Smith told The Post.
According to the inspector general's report, Brandt -- against the advice of the Park Service's chief horticulturist --
then began working on the details of the agreement with Snyder. In the rush to complete the deal, the Park Service
failed to adhere to the National Environmental Policy Act, which requires federal agencies to consider the impact of
proposed land-use decisions.
If they had, the report concludes, the Park Service probably would have discovered that the removal of the trees --
even nonnative species -- would harm the environment. That removal has caused the hill behind Snyder's house, on
Park Service property, to begin eroding, according to the report.
Snyder is now trying to get county approval to shore up a retaining wall before it crumbles into the canal,
Montgomery County officials said.
Staff researcher Bobbye Pratt contributed to this report.
2006 The Washington Post Company
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Exhibit 62
Page 1

12 of 70 DOCUMENTS

Copyright 2006 The Washington Post

The Washington Post

May 21, 2006 Sunday
Final Edition

SECTION: Editorial; B06

LENGTH: 494 words

HEADLINE: Playing Favorites;
All men are created equal, except those who own the Redskins.

BODY:
LET'S HAVE a show of hands! If you needed government approval to disregard federal environmental laws, do
you believe the half-dozen U.S. officials crucial to granting your wish would leave their downtown offices and journey
to your suburban estate to work with you? What do you think your chances of gaining their approval would be if the
deal you sought could harm the Chesapeake and Ohio Canal National Historical Park?
Of course, we all know the answers. There would be no home visits from the feds, and the deal would be dead on
arrival. But then you are not Daniel M. Snyder, owner of the Washington Redskins. You are unlikely to draw the undi-
vided attention of the National Park Service director's special assistant, P. Daniel Smith, whose job at the time was to
attend to the needs of special-interest groups, Cabinet-level officials, Congress and, apparently, other VIPs. Because of
who Mr. Snyder was and the Park Service's desire to accommodate his interests -- even against the advice of agency
biologists and horticulturists -- the Redskins owner received written agreement to cut down more than 130 trees on a
hillside between his Potomac estate and the C&O Canal. The Interior Department inspector general's office said the
agreement with Mr. Snyder left the Park Service vulnerable to charges of favoritism. How could the inspector general
rule otherwise?
Mr. Snyder desired to gain a better view of the Potomac River by removing the trees behind his estate, some of
which were reportedly nonnative species or diseased. The Park Service's biologists and horticulturalists advised against
approving Mr. Snyder's request, The Post's Tim Craig reports, contending that clearing the area would make it more
likely that nonnative, invasive species would take over the hillside, cause erosion and hurt the environment. An en-
hanced view of the river, they argued, should not come at the expense of 50,000 square feet of mature trees. Unfortu-
nately, Mr. Smith, who learned firsthand of Mr. Snyder's wish to cut the trees while having lunch at the Snyder estate,
pressured lower level officials to approve the deal even though it disregarded federal environmental laws and harmed
the C&O Park, according to the inspector general's report.
So where do matters stand? Mr. Snyder got his deal and cut down the trees two years ago, without obeying the Na-
tional Environmental Policy Act, which requires federal agencies to consider the impact of proposed land-use decisions.
Mr. Smith, the enabler, has moved upward and onward to the superintendency of Colonial National Historical Park with
a letter of reprimand in his personnel file for "overstepping his discretion."
Page 2
Playing Favorites; All men are created equal, except those who own the Redskins. The Washington Post May 21, 2006
Sunday
And as predicted by the Park Service's biologists and horticulturalists, the tree removal has caused the hill behind
Mr. Snyder's house to erode; he's now seeking Montgomery County approval to shore up a retaining wall in danger of
crumbling into the canal. When will lunch be served?

LOAD-DATE: May 21, 2006

Exhibit 63
1 of 1 DOCUMENT
Copyright 2005 Star Tribune
Star Tribune (Minneapolis, MN)
August 12, 2005, Friday, Metro Edition
SECTION: NEWS; Nick Coleman; Pg. 2B
LENGTH: 818 words
HEADLINE: Mascots get more ink than museums
BYLINE: Nick Coleman; Staff Writer
BODY:
Aug. 18 marks the 143rd anniversary of the start of the Dakota Conflict, the Indian war that raged across Minnesota
in 1862 and touched off three decades of war between the United States and the great Sioux Nation - a war that didn't
end until the massacre at Wounded Knee.
Too bad it's so hard to find out much about it these days.
In the epidemic of stupidity now stalking the land, the Lower Sioux History Center - the only museum anywhere
dedicated to telling the important story of the Dakota Conflict and exploring its causes and its outcomes - remains
closed for a second summer.
Happily, there is news that it might be open again next year. More on that later. But first, let's turn to the Indian
news that has many Americans hopping mad. It isn't the closing of a history museum, that's for sure. An Indian museum
just tells the story of the original people of the land and how their cultures were devastated by the people who stole this
country. Bit of a bummer, really. Best to avoid. Don't want to know too much. Makes your head hurt.
But don't dare mess with Indian mascots.
If we want to tap into real anger about Indian stuff, all we have to do is bring up the recent decision by the NCAA
ordering college teams with offensive Indian nicknames and mascots not to use them in postseason playoffs.
President Bush's little brother, Jeb, the governor of Florida, was outraged by the NCAA decision, which will
prevent legions of war-paint-streaked frat boys from doing the "Seminole chop" at postseason Florida State University
football games for years to come. Predictably, the school's trustees have voted to appeal the ban, which is a waste of
time. The NCAA could have been harsher and banned all Indian nicknames outright.
Instead, they settled for a kind of Goober Law:
"Dear Goober: You and all your fellow Goobers may call your teams whatever you want when you are at home, but
if you get to the playoffs, decency requires you to clean up your act for respectable folks."
Page 1
It makes sense to me, but then, I'm old-fashioned.
I think this newspaper was reaching in the same direction two years ago when it abandoned a nine-year practice of
not using offensive or derogatory nicknames, such as the Washington Redskins. Now, we use them when we have to,
but pretty much wish they would stay out of our arena.
The issue may never go away. Not as long as we have the Washington Redskins, a team patronized by powerful
politicians and lobbyists who claim its nickname is a tribute to American Indians. Well, two can play at the tribute
game.
That's why I have started calling Redskins' owner Daniel Snyder "The Vandal." Snyder, a gazillionaire, pressured
the National Park Service (and offered it money) so he could cut down 130 trees on park property (violating the law)
that blocked his view of the Potomac River.
So I call him "The Vandal," as a sort of tribute. "The Creep" would work, too.
And don't get me started about the North Dakota Fighting Sioux. Despite the near-unanimous objection of North
Dakota's Indian tribes, the Fighting Sioux logo has been chiseled on every stationary object in Grand Forks, largely due
to a $100 million gift from a late Las Vegas casino owner who had a thing for Nazi memorabilia, Hitler portraits and the
Fighting Sioux hockey team. Little known fact: UND's teams were the Flickertails until the 1930s, when fierce racial
myths came into popularity.
Put me down as one fan of the lowly Golden Gopher who is glad the good name of the Sioux will no longer be
insulted by hockey players from Canada in future postseason college tournaments.
Now back to the Lower Sioux History Center near Morton, Minn. It closed in June of last year after the Legislature
cut the budget for the state Historical Society. A clearer example of how draconian budget cuts lead to a general
dumbing-down of a place would be hard to find. Just seven years shy of the 150th anniversary of a terrible series of
events that had a profound effect on the shape of Minnesota, the museum remains closed.
That's an outrage. A real one.
"Same old, same old," says Vernell Wabasha, an elder on the Lower Sioux reservation whose husband, Ernest, is a
hereditary Dakota chief. "People seem to be more upset about losing some dumb nicknames than they are about losing
the history. It seems like Indian people always have to have our guard up. We're always being attacked."
The good news is that earlier this year, the Legislature restored some of the Historical Society's cuts so that the
Lower Sioux museum (as well as several other sites that closed last year) can reopen. The museum is expected to be
back in business next summer.
It's about time.
Who knows? Some day, we may care more about a people who were - and are - major players in the story of
Minnesota than we care about a football team's nickname.
Nick Coleman is at ncoleman@startribune.com.
LOAD-DATE: August 12, 2005
Page 2
Mascots get more ink than museums Star Tribune (Minneapolis, MN) August 12, 2005, Friday, Metro Edition

Exhibit 64

Exhibit 65

Exhibit 66

Exhibit 67

Exhibit 68

Exhibit 69

US CREDIT-Six Flags risks bankruptcy as
debt maturity looms

Thu Mar 12, 2009 4:48pm EDT
By Karen Brettell
NEW YORK, March 12 (Reuters) - Six Flags (SIX.N) is facing
a $287 million payment in maturing preferred shares in August,
which threatens to push the company into bankruptcy if it is
unable to pay or refinance the debt.
The New York-based theme park operator is struggling to
refinance its debt load as capital markets remain essentially
closed to the riskiest borrowers and the economic slowdown
weighs on theme park attendance.
"At this point, the August 2009 maturity on Six Flag's
preferreds is the looming liquidity event that has no clear
resolution," CreditSights analysts Christopher Snow and Frank
Lee said in a report on Thursday.
If the company is able to redeem its shares, known as
Preferred Income Equity redeemable Shares (PIERS), it will also
need to repay or refinance around $130 million in a bond
maturing in February 2010.
Six Flags warned on Wednesday that it may be unable to
repay the preferred shares.
"Given the current negative conditions in the economy
generally and the credit markets in particular, there is
substantial uncertainty that we will be able to effect a
refinancing of our debt on or prior to maturity or the PIERS
prior to their mandatory redemption date on August 15, 2009,"
Six Flags said in a regulatory filing.
Failure to repay the shares could accelerate payments on
its loans and bonds, which the company would be unable to
repay, Six Flags said. It added that it is exploring
refinancing options, which include a restructuring in or out of
court.
"It is clear in the current credit market that refinancing
of these issues will be nearly impossible," Barbara Cappaert,
an analyst at KDP Investment Advisors, said in a report on
Tuesday.
The options for refinancing the debt are limited and
complicated, though the company may be best served seeking a
solution that does not harm existing debtholders, CreditSights
said.
"The market capitalization of Six Flag's common equity is
about $20 million, which means that the company could offer
some value to the PIERS holders, but this would be clearly
dilutive," the CreditSights analysts said.
Fitch Ratings last month cut Six Flags to an even deeper
speculative grade of "CC," 10 steps below investment grade, and
warned that the company may pursue a distressed debt exchange.
However, bondholders would be unlikely to participate in
any proposed debt exchange, as it would fail to address the
critical maturing shares, said CreditSights.
"If Six Flags could resolve the problem of the preferreds
without offering any type of security that is senior to the
equity, the company could scrape by for quite some time," they
added.
Assuming Six Flags can redeem its preferred shares in
August, the company may then be able to refinance its bond due
in February, the CreditSights analysts said.
A successful refinancing of this bond could allow the
company to survive until 2013 when it would need to refinance
$244 million in its revolving credit line and repay $142
million in maturing bonds, they added.

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Exhibit 70
washingtonpost.com > Business > Local Business
Six Flags Declares Bankruptcy, Will Keep Parks Open
By Thomas Heath
Sunday, June 14, 2009
Theme park operator Six Flags, chaired by Washington
Redskins owner Daniel M. Snyder, declared bankruptcy
yesterday after failing to reach a deal with lenders on
$2.4 billion in debt.
The bankruptcy is likely to significantly reduce the value
of the shares held by Snyder and others in the chain,
whose 20 parks span North America and drew 25
million visitors last year. In a statement on the
company's Web site, chief executive Mark Shapiro,
whom Snyder recruited to run Six Flags, said the theme
parks will remain open and employees will continue to
be paid.
"This action to clean up the balance sheet paves the way
for a full revival of the company," Shapiro said. "We
inherited an unsustainable $2.4 billion debt load from
the previous management team." Six Flags said it filed
Chapter 11 with a prearranged reorganization plan to
reduce its balance sheet by about $1.8 billion and
eliminate more than $300 million in preferred stock
obligations due this summer.
Snyder, whose stake in the company is roughly 5 to 6
percent, and who has seen the value of his shares decline
precipitously in recent years, released a statement
yesterday backing Shapiro.
"Mark and his team have exceeded every operational
goal we set out three years ago, and Six Flags is on the
path to maintaining its growth and continuing to satisfy
millions of guests," Snyder said. "The harsh realities of
today's credit markets and the onerous debt we inherited
from previous management have brought us to this
place, but I'm confident Six Flags will emerge as a
stronger corporation."
Shapiro said that "when the reorganization process is
finished, you will see Dan Snyder making a significant
investment in Six Flags."
The bankruptcy for the 48-year-old firm follows a wild ride in recent years. Snyder took
control of the company after a bitter proxy fight in 2005. He brought in the energetic Shapiro
from ESPN to resurrect it.
Shapiro's strategy was to remake Six Flags
into a more wholesome, family-oriented experience, emphasizing safety, cleanliness and
Six Flags, which has 20 theme parks in North
America, was unable to reach a deal on $2.4
billion in debt. (By Linda Davidson -- The
Washington Post)
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customer service while forging partnerships
with major sponsors such as Sara Lee and
Chase Card Services.
The company doubled its income from
corporate sponsorship and from season ticket
sales, and it added themed attractions based
on the Looney Tunes characters, the Justice
League of America, skateboarding legend
Tony Hawk, the Wiggles and Thomas the
Tank Engine.
But its summer 2007 attendance was
slammed by bad weather in Georgia and
Texas, and by an accident on a ride at its park in Kentucky. The same year, it sold seven of its
theme parks to a Jacksonville, Fla., company for $312 million in an effort to improve its
balance sheet.
Six Flags slashed admission prices by half at several parks to improve attendance and cut a
deal in 2008 with a Dubai developer to build a theme park in the Arab emirate as part of a
huge entertainment complex. Despite improvement in operations and attendance, the
company could not get out from under its interest expense of $175 million a year, which ate
up a big chunk of earnings.
The recession made it difficult for Six Flags to refinance its obligations or to sell more
properties.
Last summer, it said it would no longer pay a dividend to holders of certain preferred shares
for the second consecutive quarter. The company was recently delisted from the New York
Stock Exchange.
Six Flags shares traded Friday for 26 cents.
Other major investors in Six Flags include Bill Gates' Cascade Investment and the hedge fund
Renaissance Technologies.

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April 29, 2010 3:48 PM
Bankruptcy Rollercoaster Over: Six Flags Headed for Chapter 11 Exit
Posted by Brian Baxter
Lawyers for warring bondholders have reached an agreement on the future of Six Flags, allowing the second-largest amusement park operator in the world to
emerge from bankruptcy just in time for its peak summer earnings season.
The settlement, between a group of bondholders led by Stark Investments and another led by Avenue Capital, was reached just an hour before the start of
confirmation hearings on Wednesday, Dow Jones reports. As part of the deal, the Stark bondholder group will pay $470 million to the group led by Avenue
Capital in order to satisfy debts of $420 million.
The $50 million in extra cash for the Avenue Capital group helped solidify the deal and secure confirmation of a bankruptcy exit plan proposed by the Stark
group. As previously reported by The Am Law Daily, the two sides had been battling for control of Six Flags since late last year. (The Six Flags bankruptcy has
had more twists and turns than some of the rides at the New York-based company's 20 theme parks.)
White & Case global financial restructuring chair Thomas Lauria, bankruptcy partner John Cunningham, and litigation partner J. Christopher Shore represented
the group backed by Stark, a suburban Milwaukee-based hedge fund. Lauria did not immediately return a request for comment.
Blank Rome bankruptcy partner Jason Staib represented Avenue Capital, while the Avenue-led group of bondholders was advised by Akin Gump Strauss Hauer
& Feld restructuring partner Ira Dizengoff.
"We supported the deal that ultimately got done," says Steven Levine, the head of Brown Rudnick's finance practice and a lead lawyer for Six Flag's official
committee of unsecured creditors. "So we should get the confirmation order today, and the actual closing that will allow [Six Flags] to emerge from bankruptcy
with new debt and equity financing should come by Monday."
Levine, Brown Rudnick bankruptcy and finance chair Edward Weisfelner, and litigation partner Andrew Dash led a team from the firm that had been working in
alliance with bondholders backed by the Stark group since early December to oppose rival bankruptcy exit plans proposed by Avenue Capital and secured bank
lenders.
As a result of the deal between the groups, bondholders led by Stark will now have complete control of Six Flags, which filed for bankruptcy in Delaware last
June. Unclear at the moment is the fate of Six Flags chairman and Washington Redskins owner Daniel Snyder, who took over the company in 2005. The current
reorganization plan in place states that current CEO and former ESPN executive Mark Shapiro will remain a member of the company's board, but that the
company cannot appoint Snyder as a director without the consent of Six Flags's new owners. (Snyder, like other Six Flags shareholders, will be wiped out once
Six Flags emerges from Chapter 11.)
Paul, Hastings, Janofsky & Walker bankruptcy partner Paul Harner and litigation partner Steven Catlett represented Six Flags in Chapter 11 proceedings. Harner
was still in Delaware on Thursday and unavailable for immediate comment.
Since Six Flags filed for bankruptcy nearly a year ago, court records show that Paul Hastings has requested compensation for more than $12 million in fees and
expenses. Cadwalader, Wickersham & Taft, which is serving as special counsel to the Six Flags board of directors, has billed for roughly $693,000. (Delaware
firm Richards, Layton & Finger is serving as local debtors' counsel.)
Brown Rudnick also found the Six Flags bankruptcy to be a lucrative engagement. The firm billed the debtor for nearly $6 million in fees and expenses through
February, according to court records. Bankruptcy boutique Pachulski Stang Ziehl & Jones, which served as local counsel to Six Flags's unsecured creditors, has
billed for nearly $152,000 through January.
Brown Rudnick's Levine says he's just glad that Six Flags's bankruptcy ride is almost over. With summer quickly approaching, Levine wouldn't mind one of the
theme park operator's signature snacks.
"A free snow cone would be appreciated," he says. "Or a funnel cake."
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Exhibit 72
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NEWS | LOCAL | POLITICS | SPORTS | OPINIONS | BUSINESS | ARTS & LIVING | GOING OUT GUIDE| JOBS | CARS | REAL ESTATE|SHOPPING
Snyder leaving Six Flags board
By Thomas Heath
Saturday, May 1, 2010; A10
Washington Redskins owner Daniel M. Snyder is leaving the board of Six Flags and losing his
equity investment in the amusement park company, a business he has chaired since winning a
proxy fight five years ago.
Snyder's departure from the board, and that of his friend and Redskins partner Dwight C.
Schar, appears to bring an end to their involvement in the company, which has been on a wild
ride since Snyder took over in 2005.
Snyder's stake in the company when it filed for Chapter 11 bankruptcy protection last June was
roughly 5 to 6 percent. The stock had declined precipitously over several years as the company struggled.
Nine people, including Snyder's handpicked Six Flags chief executive, Mark Shapiro, were named directors as part of a bankruptcy
reorganization plan submitted by the company's junior bondholders, according to a filing submitted Friday in U.S. bankruptcy court in
Delaware.
Under the reorganization plan, Snyder could not be reappointed to the board without the consent of those junior bondholders. A spokesman
for Snyder released a statement Friday that said he would not seek reappointment.
"Mr. Snyder and fellow board member Dwight Schar declined the opportunity to remain on the board of directors because of their other
business commitments," according to the statement by Snyder spokesman Karl Swanson.
The 49-year-old Six Flags collapsed last June under interest payments on $2.4 billion in debt that Snyder inherited from the amusement park
company's previous owners.
Six Flags, which owns about 20 parks throughout North America, sought under Snyder and Shapiro to create a more family-friendly
atmosphere by adding rides and attractions.
The company drew 25 million visitors in 2008, and in-park spending per customer has increased, although Six Flags has not turned a profit
under Shapiro, largely because of interest payments. The current economic climate, with unemployment above 9 percent, has made it difficult
for Six Flags to increase revenue.
Snyder took control of the company after a bitter proxy fight in 2005. He brought in the energetic Shapiro from ESPN to resurrect the
struggling business.
Shapiro's strategy was to remake Six Flags into a more wholesome, family-oriented experience, emphasizing safety, cleanliness and
customer service while forging partnerships with major sponsors such as Sara Lee and Chase Card Services.
The company doubled its income from corporate sponsorship and from season ticket sales, and it added themed attractions based on the
Looney Tunes characters, the Justice League of America, skateboarding legend Tony Hawk, the Wiggles and Thomas the Tank Engine.
But its summer 2007 attendance was slammed by bad weather in Georgia and Texas and by an accident on a ride at its park in Kentucky.
The same year, it sold seven of its theme parks to a Jacksonville, Fla., company for $312 million in an effort to improve its balance sheet.
Six Flags slashed admission prices by half at several parks to improve attendance and cut a deal in 2008 with a Dubai developer to build a
theme park in the Arab emirate as part of a huge entertainment complex. Despite improvements in operations and attendance, the company
could not get out from under its interest expense of $175 million a year, which ate up a big chunk of earnings.
In 2008, it said it would no longer pay a dividend to holders of certain preferred shares for the second consecutive quarter. The company was
delisted from the New York Stock Exchange. Other major investors in Six Flags include Bill Gates's Cascade Investment and the hedge fund
Renaissance Technologies.
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Exhibit 73
Six Flags bankruptcy fight reaches settlement
RANDALL CHASE Associated Press
Thursday, April 29, 2010
WILMINGTON, Del. Bondholders who have been fighting over control of Six Flags
told a bankruptcy judge on Wednesday that they have agreed on a revised Chapter 11
reorganization plan for the theme park operator.
Under the agreement announced in court after last-minute settlement negotiations,
holders of junior notes issued by holding company Six Flags Inc. will assume control of
the New York company. Six Flags owns 20 amusement parks across the U.S., Mexico
and Canada.
Six Flags operates three attractions in Texas: Six Flags Over Texas and Six Flags
Hurricane Harbor in Arlington and Six Flags Fiesta Texas in San Antonio.
Holders of senior secured notes issued by Six Flags Operations Inc., an operating
subsidiary, would have received about 93 percent of the equity in the reorganized
company under an earlier proposal. Under the new plan, the SFO noteholders will be
paid $470 million in cash by the Six Flags Inc. noteholders to satisfy their claims.
Thomas Lauria, an attorney for the Six Flags Inc. noteholders, told Judge Christopher
Sontchi in Delaware that all other creditors will be paid in full by the SFI group, which
put together a financing package to offer its alternative plan.
This is truly an extraordinary result, Lauria said, referring to the twists and turns the
case has taken since Six Flags sought bankruptcy protection in June 2009, burdened
by high debt and declining park attendance by economically strapped consumers.
The fate of Six Flags chairman and Washington Redskins owner Dan Snyder, whose
RedZone Capital investment group led a successful proxy fight for control of Six Flags
in 2005, was not immediately clear.
Lauria said the bankruptcy parties have agreed on six people to sit on the new nine-
member board, with three more still to be selected. The reorganization plan states that
current CEO and former ESPN executive Mark Shapiro will be among the initial board
members and will be entitled to appoint one other director. But it also states that
Shapiro cannot appoint Snyder, who like other shareholders does not stand to recover
anything in the bankruptcy, without the consent of the new owners.
Lauria indicated that a court filing identifying the new board members would be
submitted before the reorganization plan takes effect, which he said could be as early
as Monday.
The companys initial reorganization plan called for a debt-to-equity swap giving
secured lenders 92 percent of the reorganized companys common stock.
After months of discussions with debt holders and secured lenders, Six Flags dumped
its original plan and adopted one under which lenders owed more than $1 billion would
be paid in full, and holders of the senior SFO notes would receive about 25 percent of
the reorganized companys common stock, with rights to purchase an additional 70
percent.
Holders of SFIs junior notes objected to the revised plan, which would have given
them only about 5 percent of the new equity. They offered an alternative proposal that
included more than $1 billion in new debt and an equity rights offering of $725 million,
proceeds from which would be used to pay off SFO noteholder claims of $420 million
and satisfy other creditors.
Under the agreement announced Wednesday, the recovery for SFO noteholders was
bumped up to $470 million from $420 million.
Peace has broken out, said Lauria.
Six Flags attorney Paul Harner said it was important for the company to put the
bankruptcy case behind it in advance of the upcoming summer operating season.
But not everyone was pleased with the settlement.
Shareholders led by Resilient Capital Management, who stand to get nothing, objected
to the plan, saying it undervalues the company and wipes out stockholders, while
allowing undeserved bonuses for managers who drove the company into bankruptcy
but stand to acquire up to 15 percent of stock in the new company under an incentive
plan.
Sontchi rejected Resilients challenge, saying it waited too long to raise its arguments
and that, under any reasonable valuation of Six Flags, holders of common stock and
the Preferred Income Equity Redeemable Shares, or PIERS, like those held by
Resilient would be left out of the money.
I find it implausible at the highest level that further delay will result in additional value
to the estate, and additional value, or any value, to the PIERS or the other common
equity in the case, Sontchi said.
The judge also approved the management incentive plan, saying it is not an outright
grant of stock to managers but a set-aside allowing for possible bonuses. The judge
also said he believes Shapiro and his team have shown positive results and put the
company in a position to be financially successful.
2011 Scripps Newspaper Group Online

Exhibit 74
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Rangers, Six Flags took similar path to rebirth in Arlington
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By MITCHELL SCHNURMAN
mschnurman@star-telegram.com
To understand how the business world has
changed in the past two years, look no further than
Arlington.
The Texas Rangers and Six Flags, anchors of the city's entertainment district, have
gone through very public financial meltdowns, followed by pitched battles for control.
Each has emerged on the other side, reborn and revitalized. They have new ownership, new
management, a ton of new equity and a lot less debt. There's no swagger yet, but hints of a winner.
All this should thrill Arlington, which is eager to capitalize on the success of Cowboys Stadium. In the
past, new owners with the Rangers and Six Flags talked about doing nearby development but couldn't
pull it off. With healthier partners, maybe somebody can figure out a way to capitalize on the vacant real
estate around these premier destinations.
The Rangers and Six Flags are more than capable businesses, with national brands and loyal
customers. They simply had to be sized right and have the proper mix of cash and debt. Chapter 11
made that possible.
This form of creative destruction may come to exemplify the business cycle of the early 21st century,
when companies loaded up on easy money, only to confront an economy in decline. It's a safe bet that
the Rangers and Six Flags will grow organically, rather than with debt, even if it's a slower build.
The parallels between the Rangers and Six Flags are uncanny. Both had owners that expanded
recklessly, failed publicly and got into trouble when revenue fell and lenders refused to rework loans.
Hedge funds bought up their distressed debt and drove a hard bargain in bankruptcy court. Chase Bank
was the leading lender, and the lead lawyer for both winning bidders was Tom Lauria of Miami, who
threw out the first pitch at a Rangers game this month.
Each bankruptcy was contested, with creditors challenging management's reorganization plan and
wrestling for control. The lead dog prevailed with the Rangers, outlasting Mark Cuban in a dramatic
auction, while junior creditors outmaneuvered the favorites at Six Flags. Both brought a lot more cash to
the table. Ultimately, the system worked pretty well. Many senior creditors were paid off, shareholders
were wiped out, top leaders got the boot, and the restructured organizations got a fresh start.
Early signs are encouraging. Under Chuck Greenberg and Nolan Ryan, the Rangers built a big lead in
their division, despite a recent slump. Fans are flocking to the Ballpark, and beer prices were reduced.
Six Flags hired a new CEO, who led another company out of bankruptcy, and a chief operating officer
with years of theme-park experience. Much of the old regime was purged, and the corporate
headquarters was moved from New York to Grand Prairie. The company expects to save $17 million a
year on overhead simply from the headquarters move.
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Last week, Six Flags reported its first results since exiting Chapter 11, and revenue and attendance
showed nice increases, with a positive bottom line.
Every business failure is unique, and the Rangers and Six Flags have notable differences. Who knows
what Tom Hicks did with the hundreds of millions that he borrowed? With Six Flags, the choice to load up
on theme parks was understandable, if flawed.
As a business proposition, I like the Rangers' upside. The team has been an underachiever, and North
Texas could become a baseball hotbed. As Greenberg likes to say, pro sports are the best-running
reality show around.
Six Flags Over Texas is an Arlington icon, and the regional park has been insulated from the parent
company's financial troubles. When it was sold in 1998, it had separate payment schedules and
guarantees with Time Warner. More recently, the giant media company provided financing so the parent
could continue to pay on the property.
In 1997, the predecessor parent, known as Premier Parks in Oklahoma City, had $254 million in long-
term debt. A year later, after buying Six Flags and taking the name, debt topped $2 billion. It added
theme parks in Europe.
The company quickly had problems, and after 1998, Six Flags never reported another annual profit.
Revenue declined 26 percent during the past decade while borrowing climbed. Six Flags changed
management in 2005, after Redskins owner Dan Snyder won a proxy battle and put former ESPN
executive Mark Shapiro in charge.
He did a good job of cleaning up the parks and targeting more families. But annual attendance declined
by almost 10 million, or more than 29 percent, in four years. Forget about covering interest payments in
that environment.
Bankruptcy was expensive for Six Flags -- almost $83 million in professional and finance fees, plus $10
million in severance for firing Shapiro -- but it discharged a big chunk of debt. Six Flags owed $830
million Aug. 1, down from $2.7 billion before it filed for Chapter 11 last year.
The company says it will pay about $75 million in annual interest, compared with more than $200 million
a few years ago.
"These heavily leveraged companies can't cope with high interest payments and a bad economy," says
Stan Block, a longtime finance professor at Texas Christian University. "I see a lot more of this
happening in the future."
Six Flags has reined in its ambitions. The focus is on cost-cutting, improving operations and using cash
to deleverage. Despite the deep reduction in debt, Six Flags made an unscheduled $25 million principal
payment this month, underscoring its new religion.
"This is a great company that had a bad balance sheet," newly hired CEO Jim Reid-Anderson said.
That's a sanitized way of saying Six Flags borrowed a lot more than it could pay back, just like Tom
Hicks and the Rangers. Both needed a do-over, and everybody gets it now. The question is how long
executives will heed the lesson.
Mitchell Schnurman's column appears Sundays and Wednesdays. 817-390-7821
Looking for comments?

Exhibit 75

Exhibit 76

Exhibit 77
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
PREMIER INTERNATIONAL
HOLDINGS, INC., et al.,

Debtors.
)
)
)
)
)
)
)
)
)
)
)
)
Chapter 11
Case No. 09-12019 (CSS)
(Jointly Administered)
Hearing Date: Commencing on March 8, 2010
Objection Deadline: March 1, 2010
Related to Docket No.: 1226
OBJECTION OF THE OFFICIAL COMMITTEE OF UNSECURED
CREDITORS RELATED TO PROPOSED CONFIRMATION OF
DEBTORS FOURTH AMENDED PLAN OF REORGANIZATION
UNDER CHAPTER 11 OF THE BANKRUPTCY CODE
March 1, 2010
PACHULSKI STANG ZIEHL & JONES LLP
Laura Davis Jones (Del. Bar No. 2436)
Kathleen P. Makowski (Del. Bar No. 3648)
919 North Market Street, 17
th
Floor
Wilmington, DE 19899-8705
BROWN RUDNICK LLP
Edward S. Weisfelner
Andrew Dash
Diane Nardi
Neal DAmato
Seven Times Square
New York, New York 10036
BROWN RUDNICK LLP
Steven B. Levine
Jeremy Coffey
One Financial Center
Boston, MA 02111
Counsel To The Official Committee of Unsecured Creditors
16
34. These negative events significantly affected the Debtors during 2009
in at least the following ways: a) decreased attendance, resulting in decreased ticket and in-
park spending revenue; and b) creation of a challenging environment in which to obtain
budgeted sponsorship revenues and arrange new sponsorship opportunities. Each of the
foregoing directly and significantly decreased cash flow a key driver of enterprise
valuation metrics.
VI. Managements Protection Of Its Own Interests.
35. Despite the expectation of a very difficult 2009 operating season,
and shortly before the Debtors sought chapter 11 protection, the Debtors board granted
members of senior management new, more lucrative employment contracts. See Six
Flags, Inc. Form 8-K, dated April 13, 2009 (Appendix N). Under these new agreements,
management reserved for itself millions of dollars in cash and stock bonuses upon the
Debtors exit from bankruptcy. See Disclosure Statement, III.C.3.
36. The ultimate realizable benefit from the new shares to be granted to
management under the SFO Plan moves inversely with the equity value ascribed by the
Court to the Debtors operations at emergence (i.e., by depressing the valuation determined
as of the effective date, management can expect a quicker appreciation in the value of their
equity positions when the market reacts to the artificially low valuation). In addition, such
stock also will have more value to the extent that the reorganized Debtors emerge from
Chapter 11 with less debt.
37. Finally, management also negotiated millions of dollars in
performance bonuses tied to the achievement of to-be-determined financial milestones.
See Disclosure Statement, III.C.3. As at least one member of management admitted that
17
the lower the Debtors projections, the easier it will be for management to receive millions
of dollars in performance bonuses. See Antinoro Deposition. January 21, 2010 141:19
141:22. (Appendix O) The projections that will determine whether senior management
receives its performance bonuses were subsequently developed by the Debtors CEO and
CFO (Messers. Shapiro and Speed), who are themselves among the senior managers poised
to reap those bonuses. See Shapiro January 27, 2010 Dep. 14:13 - 16:7. (Appendix P)
VII. The Debtors Ever-Shifting Restructuring Strategy
And Positions Regarding Valuation and Debt Capacity.
38. Over the past ten months, the Debtors restructuring strategy has
changed repeatedly and significantly. In connection with these shifting strategies,
management and the Debtors financial advisor, Houlihan Lokey Howard & Zukin
(Houlihan Lokey) adopted or implicitly endorsed no fewer than four very different
enterprise values (ranging from $1.25 billion to more than $1.6 billion) in less than one
year a period during which the intrinsic value of the Debtors enterprise presumably
remained relatively static. They have also supported restructuring plans which would have
left the Debtors with very different debt loads.
39. Prior to the Petition Date, during April and May, 2009, the Debtors
first sought to restructure their balance sheet through a series of exchange offers
contemplating the conversion to equity of approximately $1.2 billion in SFI Note and
preferred equity obligations (the Exchange Offer Plan). Because under the Exchange
Offer Plan, the Prepetition Bank Debt and the SFO Note Debt would have been left in
place, and equity ownership in the reorganized Debtor split between holders of the
Debtors PIERS securities and SFI Note debt, the implicit enterprise value underlying this
offer, which management and Houlihan Lokey endorsed, was over $ 1.6 billion. And, the
18
Debtors would have been left with total debt of at least $1.512 billion in principal amount.
See Six Flags, Inc. Proxy Statement, dated April 24, 2009.
40. Shortly thereafter, when it became apparent that the Exchange Offer
Plan would not receive the requisite acceptance, the Debtors engaged in discussions with
Avenue Capital, a major holder of the structurally senior SFO Notes and a key member of
the SFO Noteholders Committee, regarding an alternative restructuring proposal that
would, instead, deliver substantially all of the companys equity to holders of the SFO
Notes (the Prepetition SFO Plan). See Disclosure Statement, at p. 2. The implicit value
underlying the Prepetition SFO Plan, which management and Houlihan Lokey apparently
endorsed, was less than $ 1.6 billion. And, since, upon information and belief, the Pre-
Petition Credit Facilities would have remained in place, the Debtors would have been left
with total debt of more than at least $1.1 billion.
41. When both the Exchange Offer Plan and the Prepetition SFO Plan
failed to proceed on terms and at a pace satisfactory to them, the Debtors in early June
2009 entered into negotiations with certain of their secured lenders. Id. Those discussions
resulted in yet another restructuring scheme. Under this plan, 92% of the Debtors equity
would have been delivered to their senior secured lenders (the Senior Lender Plan). Id.
at p. 3.
42. The Senior Lender Plan was later embodied in the Debtors First
Amended Joint Plan of Reorganization Under Chapter 11 of the Bankruptcy Code filed
with the Court on or about July 22, 2009. [Docket No. 239] Because the senior secured
lenders would have received 92% of the equity in the reorganized Debtors under this plan
(with SFO creditors receiving only 5% and SFI creditors receiving only 1%), the Senior
19
Lender Plan, was premised on an enterprise valuation of approximately $1.25 billion,
which again was endorsed by management and Houlihan Lokey in the Disclosure
Statement filed in August 2009. See Disclosure Statement for the Debtors Amended Plan
of Reorganization, p. 90. [Docket No. 498] And, in connection with the Senior Lender
Plan the Debtors would have emerged with debt of $750 million.
43. Last Fall, under threat from the SFO Noteholders Committee to seek
to terminate exclusivity and propose their own plan, the Debtors essentially agreed to adopt
the SFO Noteholders Committee plan under which the claims the Prepetition Lenders and
all other creditors at SFTP would be paid in full and substantially all equity delivered to the
holders of the SFO Notes (i.e., the SFO Plan). See Disclosure Statement, at pp. 2, 6. In
connection with the SFO Plan, Houlihan Lokey provided an enterprise valuation with a
midpoint valuation of approximately $1.4 billion. See id. at 101. In connection with the
SFO Plan, the Debtors have arranged term and revolver exit financing totaling $830
million.
44. On February 5, 2010, Houlihan Lokey delivered its expert report on
valuation in connection with the confirmation trial estimating the Debtors enterprise
value to be between $1.392 billion and $1.631 billion, with a mid-point of $1.511 billion
(up from the $1.4 billion mid-point valuation the Debtors relied on when they initially filed
the SFO Plan only a couple of months earlier in early November). See Report of Houlihan
Lokey, dated February 5, 2010, at 53. The Debtors valuation conclusion roughly coincides
with that reached by Lazard, the expert retained by the SFO Noteholders Committee, who
estimated enterprise value to be between $1.38 billion and $1.625 billion with a mid-
point of $1.5 billion. See Expert Report of Lazard Freres & Co, LLC, dated February 5,
20
2010, at 1; Rebuttal Report of Lazard Freres & Co, LLC, dated February 12, 2010, at 1.
13
Houlihans and The Debtors Evolving Positions on Valuation and Debt Level
$1,250
$1,400
$1,511 $1,512
$750
$830 $830
> $1,600
$600
$800
$1,000
$1,200
$1,400
$1,600
$1,800
Exchange Offer Plan
May 2009
Senior Lender Plan
Summer 2009
SFO Plan
December 2009
Houlihan Valuation
Report
February 2009
Total Enterprise Value Post-Restructuring Committed Debt
VIII. The Debtors Long Range Planning.
45. As noted above, management and Houlihan Lokey have adopted
numerous positions regarding the Debtors enterprise valuation to fit the restructuring
strategies they were pursuing at different times. Over the course of September and October
2009, management again revised their long range business plan in connection with their
pursuit of confirmation of the SFO Plan. See Speed Jan. 26, 2010 Dep. 178:18-179:21.
(Appendix Q)
46. The process by which the Debtors developed projections to support
the SFO Plan was a significant departure from the Debtors historical procedures for
budgeting and annual forecasting. In particular, rather than being based on input from a
broad range of executives at varying levels within the company, the current projections are,

13
At this point, it is not clear whether the SFO Noteholders Committee intends to seek
reimbursement from the estates for the fees and expenses of Lazard Freres under the
expense reimbursement provision of the Backstop Commitment or otherwise. In
this regard, the Official Committee reserves all rights.
66
CONCLUSION
WHEREFORE, For the reasons discussed herein, the Official Committee
respectfully requests that this Court: (a) sustain this Objection; (b) deny confirmation of the
SFO Plan; and (c) grant to the Official Committee such other and further relief as is just
and proper.
Dated: March 1, 2010 PACHULSKI STANG ZIEHL & JONES
Wilmington, Delaware LLP
/s/ Kathleen P. Makowski
Laura Davis Jones (Del. Bar No. 2436)
Kathleen Makowski (Del. Bar No. 3648)
919 North Market Street, 17
th
Floor
Wilmington, DE 19899-8705
(302) 778-6401 (telephone)
-and-
BROWN RUDNICK LLP
Edward Weisfelner
Andrew Dash
Diane Nardi
Neal DAmato
Seven Times Square
New York, NY 10036
(212) 209-4900 (telephone)
(212) 209-4801 (facsimile)
-and-
Steven B. Levine
Jeremy Coffey
One Financial Center
Boston, MA 02111
(617) 856-8587 (telephone)
(617) 856-8201 (facsimile)
Counsel for the Official
Committee of Unsecured Creditors

Exhibit 78

Exhibit 79

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549

FORM 8-K

CURRENT REPORT PURSUANT
TO SECTION 13 OR 15(D) OF THE
SECURITIES EXCHANGE ACT OF 1934

Date of report (Date of earliest event reported) April 13, 2010

Six Flags, Inc.
(Exact Name of Registrant as Specified in Its Charter)

Delaware
(State or Other Jurisdiction of Incorporation)

(212) 652-9403
(Registrants Telephone Number, Including Area Code)

(Former Name or Former Address, if Changed Since Last Report)

Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under
any of the following provisions ( see General Instruction A.2. below):

Written communications pursuant to Rule 425 under the Securities Act (17 CFR 230.425)

Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17 CFR 240.14a-12)

Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17 CFR 240.14d-2(b))

Pre-commencement communications pursuant to Rule 13e-4(c) under the Exchange Act (17 CFR 240.13e-4(c))

1-13703

13-3995059
(Commission File Number)

(IRS Employer Identification No.)

1540 Broadway, 15 Floor

New York, New York

10036
(Address of Principal Executive Offices)

(Zip Code)
th

SFIs current and future liquidity is greatly dependent upon its operating results, which are driven largely by overall economic
conditions as well as the price and perceived quality of the entertainment experience at its parks. SFIs liquidity could also be adversely
affected by disruption in the availability of credit as well as unfavorable weather, accidents or the occurrence of an event or condition at its
parks, including terrorist acts or threats, negative publicity or significant local competitive events, that could significantly reduce paid
attendance and, therefore, revenue at any of its parks. Furthermore, SFIs liquidity has been and will be directly affected by the chapter 11
filing and the resolution of the chapter 11 filing. See Risk Factors.

Since SFIs business is both seasonal in nature and involves significant levels of cash transactions, SFIs net operating cash flows
are largely driven by attendance and per capita guest spending levels because its cash-based expenses are relatively fixed and do not vary
significantly with either attendance or levels of per capita spending. These cash-based operating expenses include salaries and wages,
employee benefits, advertising, outside services, repairs and maintenance, utilities and insurance. As of December 31, 2009, changes for
the year in working capital, excluding the current portion of long-term debt, impacting operating cash flows had a positive impact of
approximately $0.9 million.

Upon emergence from chapter 11 under the Plan, SFIs total debt is estimated to be approximately $1.0 billion, excluding any
amounts under the Exit Revolving Loans. Based on the proposed terms of the Exit Facility Loans, which are subject to change, and
current interest rates, SFI expects that its annual cash interest expense will be approximately $75 million.

POSTCONFIRMATION BOARD

Reorganized SFI shall have a new board of directors, which shall consist of nine (9) directors (three (3) of which shall be
independent as defined by the New York Stock Exchange (the NYSE )). The Backstop Purchasers that collectively hold two thirds
(2/3) of the aggregate backstop commitment as shall be set forth in the Amended Equity Commitment Agreement (the Majority Backstop
Purchasers ) shall select six (6) directors to the Postconfirmation Board (at least one (1) of which shall be independent), and one
(1) director, which shall be independent, shall be selected by the Creditors Committee (such selections, in each case, to be made after
consideration of preconfirmation directors designated by Mark Shapiro to serve in such capacity). In addition, Mr. Shapiro shall serve as
an initial director and shall be entitled to appoint the remaining director; provided , however , that such remaining director shall not be
Daniel M. Snyder without the consent of the Majority Backstop Purchasers. Independent directors (including the designation and
appointment, or qualification, of a third independent director), to the extent required by the NYSE, shall be qualified to serve on
Reorganized SFIs audit committee. All directors on the Postconfirmation Board shall stand for election annually. The individuals selected
by the Majority Backstop Purchasers and the Creditors Committee to serve on the initial Postconfirmation Board shall be listed in the Plan
Supplement.

10

Exhibit 80
Promotions

Update: SIX Flagging - Post-Dan Snyder Era Opens
Today at Six Flags
Posted by Dave McKenna on May. 28, 2010 at 10:25 am
CraIty Bastards
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Win advance
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see )ULHQGVZLWK
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tickets to There Will
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13
Promotions
We'll have to wait and see iI this "culture change" we keep hearing about really
has developed out at Redskins Park. But change, iI not culture, is surely in the air at Six Flags.
The local outpost oI the nation's largest theme park chain, Six Flags America in Largo, opens its season today.
It's the Iirst opening since Dan Snyder got booted out as chairman oI the board oI the company that he steered
straight toward bankruptcy aIter taking over in late 2005. I was out on paternity leave when Snyder got the oIIicial
heave ho, and I think he got oII easy.
Six Flags creditors knocked the crap outta Snyder.
Snyder to the end acted as iI he was the man to run the company aIter it got back on its Ieet. In the original
reorganization papers Iiled on July 8, 2009, by Six Flags with the Iederal court in Delaware that was overseeing the
company's bankruptcy proceedings, Snyder planned on staying in charge. The reorganized board oI directors,
spelled out in the 8K entered with the SEC, must include "Daniel M. Snyder (who shall be designated Chairman oI
the PostconIirmation Board)."
But the big money people who took a bath during Snyder's reign at Six Flags would have none oI that. Creditors
craIted an agreement oI their own that let pretty much everybody who had a hand in the debacle that Six Flags was
stay on even Mark Shapiro, Snyder's hand-picked CEO who Irom Day One smiled Ior the cameras and blew
smoke at investors about what shape the company was in.
In a deal drawn up in early April and approved by the court at the end oI the month, the creditors said Shapiro
would be allowed to choose a director to put on the board aIter the reorganization, with one hilarious caveat: "|P|
rovided, however, that such remaining director VKDOOQRWEH Daniel M. Snyder|.|"
One sign oI the animus toward Snyder: The italics are part oI the Iiling.
So, Snyder's gone. But, he'll have a Tom Joad like presence at Six Flags Ior a while now. Wherever Iolks are paying
a $5 "convenience Iee" to print out their Six Flags tickets at home, he'll be there. Wherever rollercoaster enthusiasts
are paying to store all the items they can't bring along on the ride a service that used to be Iree he'll be there.
Wherever kids are paying $12.99 Ior a Johnny Rockets single burger, Iries and a Coke, he'll be there. Wherever
parents are paying $112 (on top oI the Six Flags admission price) Ior the right Ior their kid to iump to the head oI
the line oI the leg-chopping Superman Tower oI Power ride, he'll be there.
What a ride he had.

Exhibit 81
IeinsteinOnTheBrink
John Feinstein is the bestselling author of Are You Kidding Me? (with Rocco Mediate), Living on the Black, Tales from
Q School, Last Dance, Next Man Up, Let Me Tell You a Story (with Red Auerbach), Caddy for Life, Open, The Punch,
The Last Amateurs, The Majors, A March to Madness, A Civil War, A Good Walk Spoiled, A Season on the Brink, Play
Ball, Hard Courts, and four sports mystery novels for young readers. He writes for the Washington Post,
Washingtonpost.com, and Golf Digest, and is a regular commentator on National Public Radios Morning Edition. reud
more...

SubscrIbe

Cun`t escupe the Redskins; Winninu will Iill diminished
bundwuuon
rI, JuI 16 zo1o o:6 MIke Shunuhun, sIunders, George SoIomon, Terrv Hunson, WushIngLon CupILuIs,
WushIngLon PosL, Dun Snvder, RedskIns, WushIngLon NuLIonuIs PermuIInk
One oI Lhe munv pIeusures ubouL beIng on Lhe eusLern end oI ong sIund uL LhIs LIme oI veur Is LhuL `m noL
bomburded everv LIme Lurn on u rudIo or u TV wILh LuIk oI The WushIngLon RedskIns.

To be IuIr, WushIngLon hus Improved us u sporLs Lown sInce Lhe urrIvuI oI The NuLIonuIs, becuuse u busebuII
Leum-even u bud one-gIves peopIe someLhIng Lo LuIk ubouL und wrILe ubouL everv duv Irom Murch Lo
OcLober. ThIs veur, wILh sIgns oI hope und Lhe urrIvuI oI SLephen SLrusburg, Lhere hus been InLeresL In Lhe
NuLs LhuL goes bevond Lhe hurd-core busebuII Iuns. Even Lhe usuuIIv RedskIns-obsessed sporLsLuIk rudIo hosLs
In D.C. ure wIIIIng Lo LuIk busebuII on occusIon.

ThuL`s u mujor ImprovemenL. sLIII remember goIng on vucuLIon Lo BosLon In SepLember oI 1;8. ThuL wus
Lhe veur, oI course, oI Lhe cIussIc Yunkees-Red Sox ruce LhuL cuImInuLed In Lhe Buckv BIeepIng DenL one-
gume pIuvoII won bv Lhe Yunkees. BeIng In BosLon LhuL week wus LhrIIIIng. ReudIng The BosLon GIobe everv
mornIng wus IubuIous. One Sunduv uILernoon u IrIend oI mIne und drove Lo SuIem und GIoucesLer. AIong
Lhe wuv we swILched buck und IorLh beLween Lhe Red Sox gume und Lhe Yunkees gume-pIckIng up Lhe
Yunkees sIgnuI on u ConnecLIcuL sLuLIon. LhInk BOTH Leums won In exLru InnIngs LhuL duv.

When wenL buck Lo WushIngLon wuIked InLo sporLs edILor George SoIomon`s oIIIce. He usked how mv
week oII hud been. L wus greuL, suId. The busebuII wrILIng In BosLon Is SO good. You know, IL`s sud, vou
cun`L reuIIv be u good sporLs Lown wILhouL u busebuII Leum Lo wrILe ubouL.

George wenL buIIIsLIc, LoId me dIdn`L know whuL wus LuIkIng ubouL und bunIshed me Irom Lhe oIIIce.
wenL buck Lo mv desk, pIcked up Lhe sporLs secLIon und counLed EGHT RedskIn sLorIes. There were brIeI
wIre sLorIes on Lhe Yunkees und Red Sox. Cuse cIosed.

How ImporLunL were Lhe RedskIns Lhen-und now? Mv IrIend Terrv Hunson wus Lhe pubIIcILv dIrecLor In
Lhose duvs Ior The WushIngLon DIpIomuLs, Lhe NAS soccer Leum-whIch wus mv IIrsL beuL uL The PosL.
NeedIess Lo suv ANY pubIIcILv Irom The PosL wus u bIg deuI Ior Lhe DIpIomuLs. The DIpIomuLs oIIIces were In
RK SLudIum, u Iew vurds uwuv Irom Lhe press box LhuL wus used Ior boLh soccer und IooLbuII. L wus jusL u
IILLIe bIL more crowded on IooLbuII gume duvs.

One mornIng Terrv wus In hIs oIIIce when hIs secreLurv cume In Lo suv George SoIomon wus on Lhe phone.
Terrv prucLIcuIIv jumped ouL oI hIs chuIr. Muvbe The PosL wunLed Lo do u Iong sLorv on new couch AIun
SpuvIn? WhuLever IL wus, LhIs wus BG-Lhe sporLs edILor oI The WushIngLon PosL wus cuIIIng HM.

Hunson pIcked up Lhe phone. George wus uImosL breuLhIess. ThIs reuIIv wus BG he LhoughL. Terrv need u
Iuvor, George suId.

TrvIng Lo sound cooI, Hunson suId, WeII George, II cun urrunge someLhIng, `II cerLuInIv Lrv Lo heIp. WhuL
Is IL?

The RedskIns pIuv LheIr IIrsL exhIbILIon gume LonIghL. need Lo be sure our phone In Lhe press box Is
workIng. Cun vou wuIk ouL Lhere und check IL Ior me?

L wus uL LhuL momenL LhuL IL occurred Lo Hunson LhuL George hud probubIv never HEARD oI AIun SpuvIn.

Even Lhough `ve IIved In WushIngLon sInce gruduuLIng Irom coIIege, `ve uIwuvs IeIL somewhuL udrIIL becuuse
`ve never been ubIe Lo wrup mv urms uround Lhe IocuI Leums. huve come Lo IIke und enjov Lhe CupILuIs
even Lhough Lhe sIunders wIII uIwuvs be mv hockev Leum-unIess Lhev move Lo Kunsus CILv becuuse Lhe
poIILIcIuns on ong sIund reIuse Lo cooperuLe on u desperuLeIv needed new buIIdIng-und enjov unv
success Lhe NuLs huve unIess IL InvoIves beuLIng Lhe MeLs. `m umbIvuIenL ubouL Lhe WIzurds becuuse Lhe IusL
LIme reuIIv cured ubouL Lhe NBA, WIIIIs Reed und WuIL ruzIer were sLIII suILIng up Ior Lhe KnIcks.

Nowuduvs, wILh Lhe InLerneL und TV puckuges, someone IIke me cun eusIIv keep Lruck oI Lhe MeLs und Lhe
sIunders even whIIe IIvIng In DC. WhuL`s dIIIerenL beIng here (ong sIund) versus beIng In DC Is sImpIe:
Lhe RedskIns. BeIng In DC Lhere Is no escupIng Irom Lhem 1z monLhs u veur. Thev ure u monoIILh und Lhev
know IL, whIch Is one reuson whv owner Dun Snvder cun LreuL Lhe medIu wILh dIsduIn o percenL oI Lhe LIme
und geL uwuv wILh IL.

Snvder cume onLo mv rudur-sudIv-vesLerduv when wus In mv cur uILer hosLIng JIm Rome Irom u sLudIo In
SouLhumpLon und IIIpped on WAN, expecLIng Lo heur LuIk ubouL wheLher Lhe MeLs were goIng Lo Lrude Ior u
sLurLIng pILcher. nsLeud, Ior some reuson, Lhe hosLs were InLervIewIng new RedskIns couch MIke Shunuhun.

wus ubouL Lo hIL u buLLon Lo chunge Lhe sLuLIon when one oI Lhe hosLs usked Shunuhun ubouL hIs decIsIon Lo
go work Ior Snvder. ook, Lhere ure ubouL eIghL mIIIIon reusons (u veur) whv Shunuhun wenL Lo work Ior
Snvder. NoLhIng wrong wILh LhuL. OI course Shunuhun wusn`L goIng Lo suv LhuL so he reverLed Lo Lhe oId,
vou know no one wunLs Lo wIn more Lhun Dun Snvder, IIne.

AImosL uII owners wunL Lo wIn. Some don`L huve Lhe kInd oI monev Snvder hus buL Lhev uII wunL Lo wIn.
Snvder wunLs Lo wIn Ior Snvder; Ior hIs ego und Ior no oLher reuson. CIeurIv he hus no respecL Ior hIs Iuns
becuuse he hus gouged Lhem everv chunce he`s goLLen sInce duv one und IusL veur, when Lhev IInuIIv Lurned
on hIm uILer 11 veurs oI mIs-munugemenL, he hud hIs securILv peopIe LreuL Lhem IIke suspIcIous-IookIng
churucLers LrvIng Lo bourd un uIrpIune.

The RedskIns wIII be beLLer LhIs veur-Lhev preLLv much huve Lo be uILer IusL veur`s q-1z debucIe. Donovun
McNubb Is u cIeur upgrude uL quurLerbuck; Lhev IInuIIv druILed u IeIL LuckIe und mude ImprovemenLs In Lhe
oIIensIve IIne und Shunuhun Is un upgrude uL couch. L IInuIIv occurred Lo Snvder LhuL beIng Lhe mosL huLed
mun In WushIngLon wusn`L reuIIv u good LhIng und he hus been LrvIng Lo rehub hIs Imuge LhIs oIIseuson-
sLuvIng In Lhe buckground durIng Iree ugenL sIgnIngs; LuIkIng Lo Lhe medIu on occusIon (uImosL uIwuvs uL u
churILv evenL so peopIe HAVE Lo menLIon LhuL u bIIIIonuIre Is doIng churILv work us II LhuL somehow mukes
hIm u good guv) even jeLLIsonIng hIs Iong-LIme pIL-buII PR guv who Ioved LhreuLenIng Lhe medIu members
wILh bunIshmenL Irom RedskIns Purk II Lhev dIdn`L behuve properIv.

know II Lhe RedskIns sLurL Lo wIn LhIs IuII, peopIe In DC wIII jump buck on LheIr bundwugon so IusL IL wIII
muke heuds spIn. George SLeInbrenner wenL Irom consLunLIv booed Lo cunonIzed In New York noL so much
becuuse he chunged-uILhough he cIeurIv dId-buL becuuse Lhe Yunkees becume wInners. Snvder hus none oI
SLeInbrenner`s churm OR hIs sense oI humor. BuL II hIs Leum wIns LhIs IuII, Iew In WushIngLon wIII cure.

Muvbe `II Luke unoLher vucuLIon In BosLon In SepLember.

------------------------------
John's new book: "MomenL oI GIorv--The Yeur Underdogs RuIed The Mujors,"--Is now uvuIIubIe onIIne und
In booksLores nuLIonwIde. VIsIL vour IuvorILe reLuIIer, or cIIck here Ior onIIne purchuses

CommenLs (=)

bevoSuId....
"unIess Lhev move Lo Kunsus CILv becuuse Lhe poIILIcIuns on ong sIund reIuse Lo cooperuLe on u desperuLeIv
needed new buIIdIng"

Are vou serIous? I Wung needs u new IucIIILv LhuL budIv, Lhen LeII hIm Lo buIId IL hImseII. Whv shouId
unvone oLher Lhun Wung puv Ior hIs urenu?
rIduv, JuIv 16, zo1o 1o:zz:oo AM

AnonvmousSuId....
don'L know enough ubouL sIunders und Lhe urenu Lo huve unv sense one wuv or Lhe oLher. LhInk ILs
shorLsIghLed Lo uIwuvs suv IL shouId be done prIvuLeIv vs. pubIIcIv. Or some combo LhereIn.

ThuL suId, cun'L beIIeve vou ure buvIng InLo Lhe Shunuhun PR spIn. He husn'L won u pIuvoII gume In more
Lhun u decude -- noL sInce EIwuv, DuvIs und Lhe oLhers wuIked oII Lhe IIeId oI Lhe Super BowI In MIumI In
Jun oI '. Ls umuzIng how Iong Lhe credIbIIILv IusLs.
rIduv, JuIv 16, zo1o z:11:oo PM

MuxSuId....
AcLuuIIv he dId wIn u pIuvoII gume uILer EIwuv, beuLIng Lhe PuLrIoLs beIore IosIng Lo Lhe SLeeIers In Lhe AC
ChumpIonshIp Gume uL home. You sound IIke WIIbon.
rIduv, JuIv 16, zo1o 6:1q:oo PM

MIkeSuId....
L's been u hurd rIde Lhe pusL zo veurs beIng u skIns Iuns. GIud Snvder hus bucked oII. HopeIuIIv he see Lhe
skIns sLurL Lo wIn und conLInues Lo IeL oLhers muke Lhe kev decIsIons.
Monduv, JuIv 1, zo1o 1o:16:oo PM

ARCsLuLsSuId....
John, mukIng sLuLemenLs IIke "Lhe RedskIns wIII be beLLer LhIs veur" Is prooI LhuL vou huven'L been spendIng
much LIme LhInkIng ubouL LhIs Leum. I vou reuIIv LhInk LhuL Donovun McNubb Is goIng Lo Improve Lhe QB
posILIon, urgc vou Lo do Lwo LhIngs. One, go buck und wuLch hIs IusL Lwo gumes oI Lhe seuson uguInsL Lhe
Cowbovs IusL veur. You'II see u LIred, sIow, puLheLIc QB who couIdn'L geL Lhe buII Lo u quuIILv seL oI receIvers.
Two, compure Lhe receIvers he'II be uLLempLIng Lo Lhrow Lo LhIs veur compured Lo whuL he hud IusL veur.

L's IronIc LhuL Lhe RedskIns open uguInsL DuIIus. ExpecL unoLher sImIIur perIormunce Irom McNubb, und bv
OcLober RedskIn Iuns wIII be wonderIng whuL Bruce AIIen wus LhInkIng bv LukIng LhIs LreudIess LIre oII Lhe
EugIes hunds.
Monduv, JuIv 1, zo1o 11:q:oo PM
See OIder PosLs... SubscrIbe
John's Recent Books
z bIog
z uppeurunces
z connecL
z books
z ubouL

Exhibit 82

washingtonpost.com > Sports > Redskins FOLLOW THE REDSKINS ON:
THIS STORY: READ + | Comments
REDSKINS
Washington Redskins lose to St. Louis Rams despite injury to
Steven Jackson
By Jason Reid
Monday, September 27, 2010; 12:14
AM
ST. LOUIS - AIter making many
poor decisions in his Iirst 11
seasons as owner, Daniel Snyder
hired a proven winner in Coach
Mike Shanahan, provided support
Ior the new head oI the Redskins'
Iootball operation and moved into
the background to let Shanahan
work alone out Iront.
And it appears Snyder must do one
more thing Ior Shanahan: Be patient.
The rebuilding process could take a while, which was
evident again Sunday as the struggling St. Louis Rams
raced to an early lead and pulled away late during a 30-
16 victory over the Redskins at the Edward Jones Dome.
Although the Rams have only two victories in their last
29 games and seven in their past 51, they were 14 points
better than the Redskins, who endured a similarly
Irustrating experience last season in Week 3. That was
when the hapless Lions stunned the Redskins in Detroit.
It was the Rams in the third week this time.
Players did not envision losing to either team - but lose
they deIinitely did.
"First and Ioremost, to lose games to these teams, it's
iust very Irustrating," center Casey Rabach said. "These
Roster | Schedule | Statistics | Depth Chart | Transactions | NFL Section
Redskins falter, lose to Rams in St. Louis
The Redskins fall behind early, come back to take the lead in
the third quarter, but fade down the stretch in a 30-16 loss to the
Rams.
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THIS STORY
Washington Redskins lose to St. Louis
Rams despite injury to Steven Jackson
Tracee Hamilton: Battered by the
Rams
Thomas Boswell: Giving another down
team a lift
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are teams that we should . . . not taking anything away
Irom this team. This team is deIinitely improved Irom
where it had been. But we need to Iind ways to win this
game. We have to."
The Rams (1-2) got three Iourth-quarter Iield goals Irom
place kicker Josh Brown and repeatedly stopped the
Redskins on third down to win beIore an announced
crowd oI 52,370. The Redskins wasted a personal-best
three Iield goals by place kicker Graham Gano, who also
handled punting duties aIter punter Josh Bidwell
suIIered a pregame iniury.
They were outscored 16-0 to close the game, aIter
brieIly taking their only lead on one oI Gano's short
kicks early in the third. Washington rushed Ior only one
yard in the second halI and converted 1 oI 10 third-down
attempts in the game. St. Louis was successIul on 7 oI
16 third-down plays.
"Third downs," Shanahan said. "You kept on taking a
look at third and 10, third and eight, third and 11. They
did a great iob on their third downs. And like I said, any
time we're 10 percent . . ."
Rams rookie quarterback Sam BradIord outperIormed 12-year Redskins veteran Donovan
McNabb in the best outing oI his nascent career. "Awesome," BradIord said oI the victory.
"There's no doubt."
BradIord made plays to extend drives, which
helped the Rams overcome the loss oI star
running back Steven Jackson, who suIIered a
groin iniury late in the second quarter and did
not return to the game. For the second time in
as many weeks, the Redskins' deIense again
struggled to get oII the Iield down the stretch.
AIter an opening victory over the Dallas
Cowboys, Washington (1-2) has dropped two
in a row and next Iaces the NFC East-division
leading Eagles at Lincoln Financial Field. It
will be their Iirst contest against Philadelphia
since McNabb was traded Irom that team last
spring.

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washingtonpost.com > Sports > Redskins FOLLOW THE REDSKINS ON:
THIS STORY: READ + | Comments
REDSKINS
Washington Redskins lose to St. Louis Rams despite injury to
Steven Jackson
The Redskins are not playing well
and have problems to overcome,
players said, so it seems they may
have an even longer road back
under Shanahan than some initially
believed.
"Every year there's a team that we
should beat, that we should iump on
early and put 'em away, and they
end up iumping on us," cornerback
Carlos Rogers said. "Just like last
year |against Detroit|, they iumped
on us and we couldn't make the
plays to get oII the Iield. You iust
don't expect it. I didn't expect it."
Said deIensive lineman Albert Haynesworth: "We kind
oI expected: 'Oh, this is the Rams. We're gonna come in
here and iust beat em.' But they're an NFL team, too."
The game began horribly Ior the Redskins, who trailed
14-0 within the Iirst seven minutes. Actually, their
misIortune began during warmups, when Bidwell
suIIered an iniury to his hip, which had been
arthroscopically repaired.
"That doesn't happen very oIten," Shanahan said.
"Something popped. We are not sure what it is, but it
was his hip."
Gano, who also punted in college, sent the opening
Roster | Schedule | Statistics | Depth Chart | Transactions | NFL Section
Page 2 of 2 < Back
Redskins falter, lose to Rams in St. Louis
The Redskins fall behind early, come back to take the lead in
the third quarter, but fade down the stretch in a 30-16 loss to the
Rams.
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kickoII out oI bounds Ior a penalty beIore the Iirst play
Irom scrimmage (Later, Iilling in Ior Bidwell, he had his
Iirst punt blocked). The Rams started at their 40 and
relied on the running game.
Jackson's impressive 42-yard touchdown run capped the
opening drive. He burst through the right side oI the line,
cut back leIt and then outraced the Redskins' deIense to
the end zone.
BradIord (235 yards passing, one touchdown and one
interception) also threw a short touchdown pass in the
Iirst quarter and the crowd, sensing a good day Ior the
Rams, was into the game. The Redskins, however,
rallied in the second quarter.
McNabb (236 yards passing, one touchdown and one
interception) and Santana Moss (six receptions, 124
yards) teamed up Ior a 21-yard touchdown, Gano made
two Iield goals and Phillip Daniels provided inspiration
as the halI closed when he burst through the Rams' line
to block Brown's 21-yard Iield goal attempt.
The Redskins ran oII the Iield energized and optimistic
about the second halI. "I thought we got a lot |oI
momentum| out oI it," Daniels said. "We iust didn't get
anything out oI it, so it really didn't matter."
Backup running back Kenneth Darby scored the only touchdown oI the second halI on a 12-
yard run to help the Rams reclaim the lead the Redskins took on the previous possession.
From there, the Redskins Iailed to put together anything on oIIense and the deIense was not
much help.
Last in the NFL in deIense entering the game,
Washington again gave up more yards than it
produced. The Rams had 365 net yards and
the Redskins had 349, with 49 coming on the
Iinal drive when the game was all but over. In
three games, Washington has been outscored
aIter halItime, 46-13.
"It's very Irustrating," cornerback DeAngelo
Hall said. "You spot any team 14 points,
you're going to have to play out oI a hole and
it's diIIicult. We iust couldn't make the plays,
but we iust got to be patient and do the things
we're supposed to do."

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Exhibit 83

Hampton Roads, VA - 06/15/2011
77
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Home Sports National Sports
NFL 2010 | Can new Redskins regime earn playoff spot?
Posted to: National Sports Sports Login or register to post comments
By Tom Robinson
The Virginian-Pilot
September 9, 2010
It happens every year in the NFL.
Occasionally it happens three or four times, which
means there is clear and present hope for the
Washington Redskins.
"It" is significant improvement from one season to
the next. Not getting better by a little bit. Getting
better by at least five victories and reaching the
playoffs.
Each season since 1980, records show, an
average of two down-on-their-luck franchises have
hit on that magic coach, health, schedule or
strategy to leapfrog toward prosperity.
There are 69 examples in that span, not including
two seasons shortened by labor strife, of teams
spiking by five wins or more. They became playoff
teams 83 percent of the time, and sometimes they
became much more.
This should sound familiar. In just the past two
seasons, eight franchises - four per year - fit this
mold. One of them, the New Orleans Saints, won
the most recent Super Bowl. The Saints, 8-8 in
2008, won 13 regular-season games last year, then
their first league championship.
But Cincinnati, San Diego and Green Bay also rose
like this in '09, and the year before, Atlanta,
Baltimore, Carolina and Miami (which won a
whopping 10 more games) burst from mediocrity or
worse.
That, of course, describes how new coach Mike
Shanahan found the Redskins - worse than
mediocre, based on their 4-12 record. That dismal
season, the second and final one of Jim Zorn's
tenure, left Washington out of the playoffs for the
14th time in 17 years.
That is rare NFL futility. Since 1993, only five teams
have made fewer than four playoff appearances.
But of them, New Orleans is reigning champ.
Cincinnati won 10 games last season. And Arizona
reached the Super Bowl two years ago.
This means Washington, with three appearances,
and the Cleveland Browns (two) are the long-term
INTERACTIVES
Tracker: How does your team
stack up?
Power rankings: Each team's
strengths and weaknesses

GAME-BY GAME
z Sept. 12 Dallas, 8:20 p.m.
Tom says Its close, but my NFC East pick ruins
Mike Shanahans debut in first Skins-Boys
opener since 1999. (Record 0-1)
z Sept. 19 Tom says Perennial underachieving
Texans stumble to 0-2 start after opening-day
loss to Colts. (1-1)
z Sept. 26 at St. Louis, 4:05 p.m.
Tom says Redskins win this one even if they
play with their cleats on the wrong feet. (2-1)
z Oct. 3 at Philadelphia, 4:15 p.m.
Tom says Buildup for Donovan McNabbs return
to Philly is relentless but, wound too tight, No. 5
falters. (2-2)
z Oct. 10 Green Bay, 1 p.m.
Tom says Aaron Rodgers picks apart Skins
coverage in just the Packs third trip to
Washington in 31 years. (2-3)
z Oct. 17 Indianapolis, 8:20 p.m.
Tom says Redskins stay 0-for-October after
tough back-to-back losses to my respective
Super Bowl favorites. (2-4)
z Oct. 24 at Chicago, 1 p.m.
Tom says Bears QB Jay Cutler, on pace to set
interception record, chucks five more, Skins get
off their three-game schneid. (3-4)
z Oct. 31 at Detroit, 1 p.m.
Tom says Skins successfully conclude
Midwestern tour, but rampaging Lions rookie
Ndamukong Suh snaps off McNabbs helmet,
with head still inside. (4-4)
z Nov. 15 Philadelphia, 8:30 p.m.
Tom says Prime-time revenge rained upon the
Eagles allows Redskins to stay in the hunt for an
NFC playoff spot. (5-4)
z Nov. 2 at Tennessee, 1 p.m.
Tom says Skins suffer just second road loss
when they yield 200 rushing yards in a game
darn you Chris Johnson! for the first time since
06. (5-5)
z Nov. 28 Minnesota, 1 p.m.
Tom says A trap game for the Vikings, who play
host to the Packers the week before, but two
TDs by Percy Harvin help barely sink Skins (5-6)
z Dec. 5 at New York Giants, 1 p.m.
Tom says Nothing new in Redskins first regular-
season visit to new Meadowlands but their
eighth loss in last nine against Giants (5-7)
z Dec. 12 Tampa Bay, 1 p.m.
Tom says Skins pound the Bucs, who could be
honorary NFC East members; since 03 these

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dregs. Not only that, but the Redskins historically
aren't a quick-fix outfit. Not counting the '82 strike
season, Washington hasn't shown five-win
improvement since 1955.

But wait...
Hope springs eternal in sports. Never mind that The
Washington Post recently computed five-win
reversals in the first year of a coaching regime have
happened only about 15 percent of the time since
1990.
They still happen, most notably Miami's move
under Tony Sparano from 1 to 11 victories in '08.
True, it's unclear how bad the '09 Redskins truly
were, considering they lost by a field goal five times
despite a top-10 defense. It's very possible they are
less than a miracle away from realistic playoff
dreams, but fans be warned:
Nine wins are all but essential in the NFC East. The
'06 New York Giants are the only division team in
the past decade to make the playoffs at 8-8.
Regardless, Shanahan wasn't buying the "Yeah,
but" view when he was hired in January: "If you're
4-12," he said, "you're 4-12."
Yeah, but... an experienced general manager,
Bruce Allen, is in the executive suite. New offensive
and defensive schemes are in the game plan. Six-
time Pro Bowl quarterback Donovan McNabb is in
the huddle. Owner Dan Snyder, famous for
meddling, has claimed he's in the background. And
Shanahan, who won Super Bowls with the Denver
Broncos in '97 and '98, is on the field.
The latter, especially, makes an immediate difference, said cornerback DeAngelo Hall of Chesapeake.
"When you see Super Bowl rings and the resume he has, you just tend to fall in line a little quicker," Hall
said.
But can it make a big enough difference immediately?
"I can't tell you how long it's going to take," Shanahan has said, "but I guarantee you one thing... we'll
get better every day."

The Redskins better get better.
Their schedule includes 10 opponents that either made the playoffs last year or beat Washington. As
Shanahan reminded, the Redskins are 4-12 until further notice. And obstacles beyond the schedule
loom.
Age and lack of offensive depth, just to name two.
The Redskins, according to ESPN.com last season, were the league's oldest team, at an average age
just over 28, and that isn't something that changes quickly.
McNabb, who will be 34 in November, stayed healthy enough over the last six of his 11 seasons in
Philadelphia to play an entire schedule once. And McNabb is backed up by the pedestrian Rex
Grossman, he of the 54 percent career completion percentage.
As for the rest of the backfield, it's declining and elderly, in football terms. Clinton Portis (29) and Larry
Johnson (30), who are coming off career-low seasons, hardly skew young. And beyond Santana Moss
(31), who caught 70 balls last season, Washington's younger receivers are unproven as playmakers.
That, then, has sparked the popular notion that the Redskins offensive coordinator, Shanahan's son
Kyle, will be quick to use Chris Cooley and Fred Davis in two tight-end sets, which Cooley said he
wouldn't mind a bit.
"It sets up play-action, and along from that you can spread it out and throw the ball," he said. "So
defenses will have to guess. A big thing that defenses do is see what personnel is in the game and then
they can play percentages. I think we can be 50-50 (run and pass), and that can be a huge advantage
for us."
honorary NFC East members; since 03 these
teams have met every year except 08. (6-7)
z Dec. 19 at Dallas, 1 p.m.
Tom says A dismal divisional record for
Washington gets worse (1-4) on this pre-
Christmas visit to Jerrys World. (6-8)
z Dec. 26 at Jacksonville, 1 p.m.
Tom says Jaguars, endangered in North Florida,
wont care by this point, nor will whatevers left of
their public. (7-8)
z Jan. 2 New York Giants, 1 p.m.
Tom says The first season of Shanahan ends
with momentum from a two-game winning
streak, but no playoff berth. (8-8)
RELATED
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NFL 2010 | League still in troubled financial
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NFL 2010 | What to expect this season - Sep. 9,
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Washington's long-neglected line does look better, though, because Shanahan addressed it about as
quickly as he jettisoned Jason Campbell for McNabb.
Almost incredibly, before this year the Redskins hadn't used their first draft pick on a blocker since
1996. That changed with Oklahoma's Trent Williams, the new left tackle.
Meanwhile, veteran center Casey Rabach, who with holdover guard Derrick Dockery has watched the
remake with more than casual interest, said he appreciated the signings of tackle Jammal Brown from
New Orleans - though Brown's been hurt in the preseason - and guard Artis Hicks from Minnesota.
"I think we can be as good as we want to be," Rabach said. "If we buy in... I think we can be pretty darn
good."
Shanahan's presence obviously is a huge factor in that feeling of promise. Deep Creek's Hall, leaving
the practice field at Redskins Park one morning in July, smiled when asked what he'd previously known
of his new head coach.
"Ah, you mean the legend and the myth, huh?" Hall said. "Personally, I didn't know a lot about him, but
from afar I know players respected him and his teams. I only had a chance to play against him once
when I was in Oakland. They really schemed us up, played to their strengths and our weaknesses.
"As a defensive player, you feel like you can always win as long as your team is doing that."
Now, though, Shanahan and defensive coordinator, Jim Haslett, will scheme in a way that's new to
Redskins fans, and that's another point of speculation.
The Redskins have joined the wave to a 3-4 base alignment. This, among other irritants, irked their
behemoth, space-eating tackle Albert Haynesworth - maybe you've heard about this - because, he has
said, his responsibilities in a 3-4 aren't what he signed up for last year when he bolted Tennessee for a
$100 million free-agent deal.
Haynesworth's attitude, cooperation and lingering bad health are legitimate defensive issues entering
the season. But aside from all that, is such a philosophical switch a needless risk for a unit that was
10th in the NFL last year in fewest yards allowed (320 per game)?
It's no risk if turnovers are the golden ticket, which they apparently are given the Redskins' preseason
emphasis. The problem: Washington just doesn't steal away the ball much. It was last in the league a
year ago with 17 takeaways, and 18 the year before were third-worst.
But in the 3-4 world, according to end Phillip Daniels, the regular presence of four linebackers disguises
blitzes and coverages, the better to confuse offenses and pop footballs loose.
"The key is keeping the offense off-balance," Daniels said. "You never know what you're gonna get.
You never know where we're gonna be or who's coming."
And that makes for "a nasty scheme," said second-year linebacker Brian Orakpo, a converted end
who's had to cram on pass-coverage skills. "I'm excited. I know everybody else is excited to see the 3-4
in full go."
The Redskins, Hall said, even have packages that put "seven or eight linebackers out there at one time.
You got all these guys who can play defensive end but are good at linebacker, and a couple linebackers
that can play defensive end.... That's gonna give us the chance to keep speed on the field."
In his seventh season, Hall, 26, still boasts much of that speed and quickness. It helped him intercept
four passes last season, his first full one with the Redskins. And the new defense, he said, won't
necessarily affect how he plays receivers.
Actually, Hall suspects it extend his career, and that makes him smile, too.
"Deshea Townsend, how long's he played in this 3-4 Pittsburgh style of attack, sitting back, reading
routes, catching balls?" Hall said of the current Colts cornerback entering his 13th season.
"When I came out of Virginia Tech, I had visions of being in this league for a long time, and that's what I
want to do. I want to be like Charles Woodson, Troy Vincent and Darrell Green, these guys who just
keep playing."

Ah yes, the playing.
Talking inevitably yields to the reality of the field. And here's another hopeful reality for a team like the
Redskins looking for a quick bounce-back:
In every season since '97, at least two teams have improved by five wins. And you need to reach all the
way to 1986 to find the last season when no one went five-plus.
So yes, it's going to happen this year - in all likelihood. Why, then, not the Redskins, thin spots and all?
"It's one of the best things about the NFL," Cooley said. "There's always the possibility that anyone can
come together and be good.... We're very excited about the prospects that the Washington Redskins
can be a playoff team."
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Cooley's optimism will be tested out of the gate, no question. Among teams that didn't win seven games
last year, the Redskins have the harshest road, according to the NFL's strength of schedule.
In the first six weeks, the Redskins play presumed playoff contenders Dallas, Houston, Philadelphia,
Green Bay and Indianapolis. Houston won nine last year, Indy won 14 and the other three won 11.
Which means it should be evident by mid-October whether the Redskins have postseason potential in
Shanahan's first season.
The coach's previous two "debut" teams did not. Shanahan improved the '88 Los Angeles Raiders by
two wins and the '95 Broncos by one, but neither made the playoffs.
It's worth noting, though, that while Shanahan was fired early the following season by the Raiders, his
second Broncos team won the AFC West, and his next two won the Super Bowl.
Given Shanahan's famous intensity, eye for detail and success - just three losing records in 15 full
seasons - it's no surprise he's come to Washington expecting results and expecting them now.
"That's what you should expect, and that's what the fans should expect," Shanahan said in January on
the Redskins' website. "To go through a season 8-8 in Denver, I didn't want to go out, I didn't want to
eat. You're embarrassed, because it's your name on the football team."
It could be Shanahan won't feast immediately. But famine? History suggests the Redskins' recent lean
days are done.
Tom Robinson (757) 446-2518 tom.robinson@pilotonline.com

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PREDICTION
McNabb out for the year with an injury by game 3.

Submitted by russb757 on Thu, 09/09/2010 at 11:13 am.
Login to your account to post comments report violation hide all comments from this user
0 or 0
LETS GO!!!!!!
as a cowboys fan i see this game to be very good. it could go either way. if the redskins can develop
the passing game which is unlikley then i think it will be close. no matter how good or bad both
teams do it is always a good game to see

Submitted by blasian757beats on Thu, 09/09/2010 at 9:26 am.
2 or 0
THIS ONE'S TOO EASY
NO

Submitted by sfumato on Thu, 09/09/2010 at 9:26 am.
2 or 0
I SEE SKINS AT 5-11 SO DON'T
I see Skins at 5-11 so don't get your hopes up.

Submitted by steveh3 on Thu, 09/09/2010 at 8:07 am.
2 or 0
THIS ARTICLE WAS TOO LONG,
so I stopped reading it.
Submitted by self ed.opine on Thu, 09/09/2010 at 2:15 am.

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Raven's seem to have the Skin's number already.

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Tanya Snyder: Redskins owner "has better people
around him now"
By Dan Steinberg

Daniel Snyder has had a noticeably increased public presence in recent
months, and the same could be said of his wife. Tanya Snyder has
appeared in an ad for NFL apparel, traveled to Indianapolis for an NFL
Play 60 event, spoken at length with the New York Times, and
spearheaded the promotion of Saturday's Fit For You 5K at National
Harbor.
To help promote the latter event, she went on TBD's Sports Talk with
Julie Parker and Alex Parker this week, and after they talked about the
Play 60 and apparel stuff, they started talking football. Alex Parker, for
example, asked Tanya Snyder about her husband's increased media
presence.
"I think he has better people around him now," she said. "I think he finally
has gotten to the point where he does have a general manager, he has
really good marketing people and I think he's grown and he's evolved
and he's very comfortable where he is. And I think he knows he's got the
right group of people around. It feels like a new beginning now. We're
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just really happy to be where we are."
She said she and her husband will see from two to eight movies on
weekends. She said Dan Snyder doesn't have a BlackBerry and prefers
texting. She said it's hard to shop for his upcoming birthday because "the
only thing Dan Snyder really wants for his birthday is -- listen up., D.C. --
a Super Bowl. I mean, that's all he wants. That's all he wants."
And she was asked about the Snyder family's reaction to D.C.'s crazed
Redskins obsession.
"We celebrate the victories just like everybody, and the losses are
devastating," she said. "I mean, very devastating, just like everybody
else. He listens, he cares, and he wants more than anything just to get it
fixed. And mainly now, he feels very confident that he has really good
people in place. So I think he believes in them and he wants them to do
their jobs and get it right."
Also, the hosts joked with Tanya Snyder about wearing clothing with the
Cowboys star. Apparently, you don't joke about that.
"Dan Snyder will rip a little star off PJs," she said. "We have to be very
careful with that type of thing. I mean, I even tried to sell him on with
young kids, night night stars [as decorations] and all that. No stars."
By Dan Steinberg | November 11, 2010; 2:26 PM ET
Categories: Media, Redskins

Save & Share:
Previous: Clinton Portis's Phillies hat
Next: Colin Cowherd now doesn't like John Wall's dad

There radio show is terrible. Almost as bad as wise but lets be honest nothing is that
that bad. Happy veterns day.
Posted by: remaxjon | November 11, 2010 2:47 PM | Report abuse
"I think he has better people around him now," she said. "I think he finally has gotten
gotten to the point where he does have a general manager"
...a.k.a. he is not Jerry Jones...
" he has really good marketing people"
...can't argue this point. Good time for the Snyders to point out that they're doing
things that Jerry Jones never would.
Posted by: ThisGuy | November 11, 2010 2:52 PM | Report abuse
My guess is it is a phase. When Shanny fails or leaves after being burned out, he'll
go back to his traditional way of doing business. At the very best it is a ten month
span in the right direction to atone for the last ten years of frustration. Larry Michael
is still the mouthpiece of the organization, and until that changes, they've still got
work to do.
Posted by: dclance | November 11, 2010 3:04 PM | Report abuse
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Exhibit 85
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Sports
PRO OOTBA; RedskIns Ire SchoLLenheImer und Muv HIre SpurrIer
Lo RepIuce HIm
By MIKE FREEMAN
Published: January 14, 2002

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operuLIons, IInIshed hIs IIrsL seuson wILh Lhe RedskIns wILh un 8-8 record uILer un o-= sLurL.
The RedskIns suId Lhev IIred SchoLLenheImer becuuse he reIused Lo reIInquIsh some oI hIs
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''Our decIsIon wus u dIIIIcuIL one und bused on phIIosophIcuI munugemenL Issues, noL on
couchIng ubIIILv,'' Snvder suId In u sLuLemenL. ''We wIsh MurLv uII Lhe besL In hIs IuLure couchIng
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SchoLLenheImer wIII receIve Lhe $;.= mIIIIon remuInIng on Lhe Iour-veur, $1o mIIIIon conLrucL he
sIgned u veur ugo.
Snvder suId Lhe RedskIns wouId hIre someone Lo oversee pIuver personneI muLLers. ''L Is verv
dIIIIcuIL Ior one IndIvIduuI Lo successIuIIv perIorm Lhe heud couch duLIes whIIe muInLuInIng
responsIbIIILv Ior scouLIng und pIuver personneI IuncLIons,'' he suId.
OLher Leums huve uIso been bIddIng Ior SpurrIer's servIces, und N... oIIIcIuIs suId IL wus sLIII
possIbIe, Lhough unIIkeIv, LhuL unoLher Leum couId snuLch SpurrIer Irom Lhe RedskIns wILh u
beLLer oIIer.

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Lhev cunnoL unLII Lhe Ruvens ure eIImInuLed Irom Lhe pIuvoIIs.
N... execuLIves suId SpurrIer hud begun ussembIIng u sLuII und wus LeIIIng poLenLIuI ussIsLunLs
LhuL he pIunned Lo Luke Lhe job wILh WushIngLon. AL IeusL Lwo oI Lhe couches he wunLs Lo hIre
were ussIsLunLs wILh hIm uL IorIdu. SpurrIer couId noL be reuched Ior commenL.
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PRO OOTBA; RedskIns Ire SchoLLenheImer und Muv HIre SpurrIer
Lo RepIuce HIm
Published: January 14, 2002
(Puge z oI z)

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SchoLLenheImer's dIsmIssuI IIIusLruLes Lhe dIIIIcuILv oI Lhe couchIng proIessIon. Owners,
especIuIIv ones us ImpuIsIve us Snvder, huve IILLIe puLIence. OLher dIsmIssuIs ure expecLed LhIs
week. Tumpu Buv Buccuneers execuLIves wIII meeL wILh Couch Tonv Dungv on Monduv Lo
dIscuss hIs IuLure. Dungv Lurned uround one oI Lhe worsL IrunchIses In sporLs buL hus noL won u
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Tumpu Buv IosL Lo PhIIudeIphIu, 1-, In u wIId-curd gume SuLurduv. Dungv's ugenL, Ruv
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The SL. PeLersburg TImes reporLed rIduv LhuL Lhe Buccuneers uIreudv hud u LenLuLIve deuI In
pIuce wILh BIII PurceIIs, Lhe Iormer GIunLs, PuLrIoLs und JeLs couch. PurceIIs denIed Lhe reporL.
eugue oIIIcIuIs suId Loduv LhuL PurceIIs hud sLIII noL decIded II he wouId couch uguIn. PurceIIs
couId noL be reuched Ior commenL.
The couchIng curouseI begun spInnIng wILh Lhe IIrIng oI Lhe Sun DIego Churgers' MIke RIIev on
Dec. 1, Lhe duv uILer LheIr reguIur-seuson IInuIe. MInnesoLu Lhen IIred DennIs Green on Jun. q,
wILh one gume remuInIng In Lhe VIkIngs' seuson. Then CuroIInu IIred George SeIIerL und
ndIunupoIIs IIred JIm Moru.

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Sunday, January 13
Updated: January 14, 7:42 PM ET

Schottenheimer out, Spurrier in for Redskins
ESPN.com news services

Redskins owner Daniel Snyder and coach Marty Schottenheimer iust couldn't Iind a
middle ground. Monday, he was oIIicially Iired as Washington's head coach, to be
replaced by Iormer Florida coach Steve Spurrier.
AIter nearly a week oI discussions, an accommodation in which Schottenheimer might
keep control oI personnel decisions and Snyder could bring in a general manager under
his rights outlined in the coach's contract, the pair parted ways Sunday night.
AIter a meeting earlier in the day leIt the two sides no closer to a resolution oI their
diIIerences, Schottenheimer was summoned again to a 7:30 p.m. ET meeting and was
released Irom the Iinal three seasons oI his Iour-year, $10 million contract, ESPN.com's
Len Pasquarelli and Chris Mortensen reported.
Snyder was also able to get Spurrier on
board to replace Schottenheimer, and
sources said the Iormer Florida Gators
coach has agreed to a Iive-year, $25-million
deal that makes him the highest paid coach
in the NFL. Spurrier will be introduced on
Tuesday.
"Snyder never would have Iired Marty
without having Spurrier in place," a league
source said.
Schottenheimer will receive the $7.5
million in base salaries due him over the
next three years.
Schottenheimer addressed the media
Monday morning and conIirmed Snyder's
decision to strip him oI total control over
personnel matters was the reason Ior the
dismissal.
"The issue we could not resolve was the
process oI selecting players to make up the Washington Redskins roster,"
Schottenheimer said. "The opportunity to determine the composition oI the Washington
Redskins was the single most element oI my taking the iob here last January.
"It was my belieI that my way would have been the most successIul, but Daniel Snyder
owns the Washington Redskins. He made the commitment to the organization and he is
entitled to make any decision he chooses."
A Fair Schott?
An argument could be made that Marty
Schottenheimer was not given a fair
chance. Joe Gibbs also started 0-5 and
finished 8-8 in his first season as
Redskins head coach, but he would go
on to win the first of three Super Bowl
titles the following season and coach
Washington for 12 years. All
Schottenheimer will get for this year's
turnaround is a pink slip. The Redskins
were one of nine teams this season to
go 8-3 or better from Oct. 21 on, but
each of the other eight teams reached
the playoffs.
Gibbs
1981
Schottenheimer
2001
Start 0-5 0-5
Finish 8-8* 8-8
Final
tenure
12 yrs. 1 yr.
*Won Super Bowl in next season

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The team subsequently issued a statement in which Snyder said that Schottenheimer was
released Irom his contract, not Ior any coaching reasons, but rather "because oI
philosophical management issues." The statement noted Schottenheimer had been
oIIered various paradigms in which he could have retained his iob. A Redskins source
said Schottenheimer had "a ton" oI opportunities with "very palatable" options that
would have kept him with the team.
Schottenheimer, 58, exits the Redskins, and perhaps the NFL Ior good, with a career
coaching mark oI 158-104-1. The 12th-winningest coach in NFL history, he was 8-8 in
Washington Ior the 2001 season.
Schottenheimer didn't rule out a return to coaching.
"You're away Irom anything Ior a couple oI years, and you think that you're still capable
but you're not sure," Schottenheimer said. "Having been back Ior a year, I can do it."
Schottenheimer said he never considered giving up his authority over player decisions,
which Snyder gave him in an eIIort to prove hands-oII ownership.
"Dan Snyder and I have agreed on many things. ... Our only diIIerence was the means by
which we would achieve it," Schottenheimer said.
Schottenheimer said in his next iob he wouldn't necessarily demand the absolute control
he thought was necessary under Snyder.
No decisions have been made regarding Schottenheimer's coaching staII, which includes
his brother and his son. Most -- iI not all -- will probably not be retained.
While Snyder Ielt Schottenheimer's iob as coach was acceptable, the owner was
perplexed by Schottenheimer's decision to release Iullback Larry Centers, who was
signed by BuIIalo and had a Pro Bowl year. Schottenheimer also stuck with JeII George
-- with no experienced backup -- through training camp even though it was apparent the
quarterback didn't Iit Schottenheimer's West Coast system.
Those decisions, and the early losing streak, soured a Snyder-Schottenheimer
relationship that started out so well. The two vacationed in Europe together, the coach
called the owner "Dan" in public, and they even wore matching straw hats at training
camp.
The 'Skins started the campaign 0-5, then rallied to win eight oI their Iinal 11 games.
Even some older veterans, who balked at Schottenheimer's conditioning and practice
methods in training camp, played much harder Ior him in the second halI oI the year.
By the end oI the season, Schottenheimer and Snyder were speaking less oIten, and
Schottenheimer was calling the owner "Mr. Snyder."
But the contract that Schottenheimer signed provided Snyder the explicit right to hire a
general manager or a Iront oIIice executive with general manager-type responsibilities.
Schottenheimer Iooled some observers early last week when he seemed ready to
reconcile the possible addition oI a general manager. He told his Iriends that he respected
Snyder Ior having spent more than $800 million to purchase the Iranchise and that he
ought to be able to hire people to oversee things.
But other issues remained and the two sides couldn't resolve them.
Team sources said that options presented to Schottenheimer on Sunday would have
allowed him to make personnel decisions in the event oI a disagreement over speciIic
players. But ESPN.com has learned that Snyder requested that Schottenheimer also
replace vice president oI personnel John Schneider and oIIensive coordinator Jimmy
Raye.

Print story


The coach originally reIused to do so but, aIter the sides adiourned their Iirst meeting,
was said to be considering the changes. He never got the chance to change his mind,
because Snyder acted by releasing him Irom his contract.
Spurrier will become the Iourth head coach Ior Snyder in his brieI stewardship oI a
Iranchise that he legitimately loves and wants desperately to be successIul. Snyder
inherited Norv Turner, Iired him last December and replaced him with interim coach
Terry Robiskie, who was released at the end oI the season. Then there was
Schottenheimer and now Spurrier will add to the list.
Information from ESPNs Chris Mortensen ana Len Pasquarelli. along with the
Associatea Press. was usea in this report.

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Breaking Camp
By Dave McKenna on July 21, 2000
A lot oI Iolks called Daniel Snyder a creep when word got out that he'd charge admission to Redskins training
camp, which opened this week in Ashburn, Va. For many Ians, the heretoIore Iree preseason workouts were the
only way to ever get close to their heroes.
Michael Jordan, meanwhile, has taken no heat Ior trying to move the Wizards' next camp out oI the range oI local
hoops Ians.
In time, Snyder probably will get creepy. But on the whole, his new camp setup is, iust as he's billed it, a good thing
Ior any Skins booster hard-core enough to actually want to watch the big boys hurry up and wait through two-a-
days (and a great thing Ior media types who have to suIIer through the tedious workouts).
The new owner's decision to break the contract that Jack Kent Cooke signed with Frostburg surely won't sit well
with oIIicials and merchants oI the tiny Western Maryland town that hosted the last Iew training camps. The team
had no proIound historic ties to that locale, however. Cooke didn't place the camp in Frostburg until 1995: prior to
the move, the Skins summered in Carlisle, Pa., since the early '60s. Cooke made the change oI venue only to satisIy
state oIIicials, who arranged Ior all the public monies he needed to build the stadium that no longer bears his name
in a town (Ralion) that no longer exists.
Classifieds
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Although camp was Iree under Cooke, Frostburg is more than 140 miles away Irom downtown D.C., and the round
trip to the campus site and back--scenic as it was--requires about six hours oI driving. The move to suburban
Redskin Park will save more than time: Given that gas now goes Ior an average oI $1.68 a gallon, Snyder will also
be saving all those SUV-owning Ians--and news organizations--a pretty penny by cutting the commute. True,
parking at Redskin Park will cost $10 and adults will have to pay $10 to watch practice, and the Skins are the Iirst
team in NFL history to exact such Iees. But children always get in Iree to Dannyworld.
Wizards Ians wishing to stalk their heroes in camp, however, will no longer have such a luxury.
And they have only Jordan to thank.
As things now stand, the Wizards' next camp will be held in Wilmington, N.C. That city was chosen Ior one oI two
reasons: (a) because Dawson's Creek is Iilmed there, or (b) because it's Jordan's hometown. In late May, Jordan sent
his girl Friday Wes Unseld on a mission to Iind a location in the Tarheel State where the team could train this Iall.
A Iew weeks aIter Unseld was dispatched, the Wilmington Morning Star ran a Iront-page story saying that the
administration oI the University oI North Carolina-Wilmington had worked out an agreement that would give the
Wizards use oI Trask Coliseum on campus and the new students-only Iield house Ior about two weeks in early
October. Local basketball coaches and others who remember Jordan Irom his days at Laney High School, where he
was cut Irom the J.V. squad on his way to deiIication, told the paper how great it's going to be to have Mike home
again.
School oIIicials also hailed the move to coastal Carolina.
"This is a beneIit Ior everybody," said Peg Bradley-Doppes, UNCW's director oI athletics.
Well, perhaps not everybody. Wizards Ians in this area, Ior example, don't beneIit Irom the move. Neither Jordan
nor the Wizards have yet conIirmed the camp transIer. But iI it happens, iust as Snyder broke sorry new ground by
charging admission, Jordan's tact is an unprecedented aIIront to his team's boosters.
Since Abe Pollin bought the Chicago Zephyrs in 1963 and moved the Iranchise east, the Bullets/Wizards have
never held camp outside our region. Bullets preseason workouts took place in Fort Meade, Md., Irom 1964 until
1988, when they were shiIted to Gettysburg, Pa. AIter a year near the battleIields, Unseld took over as coach and
camp was moved to Emmitsburg, Md. From 1992 on, Shepherd College in Shepherdstown, WVa., has been the
team's Iall home.
Although most residents oI the nation's capital preIer not to be linked with anything West Virginian, the Iederal
government does classiIy Shepherdstown as part oI the Greater Washington Metropolitan Area. And Ior all the
psychic distance between here and there, the atlas says it's only 67 miles away Irom our downtown.
Plus, because it's so close to historic sites like Antietam and Harper's Ferry, Shepherdstown is a Iine target Ior a day
trip. Last year, as part oI the Wizards' eIIort to restore a relationship with Ians damaged by several seasons oI
lackluster play and oII-court malIeasances by Iolks like Rod Strickland, Juwan Howard, and Chris Webber, the
organization loaded season-ticket holders on a bus downtown and hauled them to Shepherd College. AIter a meal in
their honor, the supporters watched an intrasquad scrimmage, then got autographs Irom the players. Nobody got
home too long aIter bedtime.
It's saIe to say that there won't be a similar Ian-Iriendly event at Jordan's Iirst camp. According to Mapquest,
Wilmington is 384 miles Irom D.C., and a drive there should take more than seven hours.
In Iairness to the new boss, Ians who so choose can make their own way to Wilmington. Flights, Ior example, are
available Irom all local airports to Jordan's hometown. US Airways oIIers the best deal Ior a day trip: To get back
and Iorth Irom Reagan National Airport to Wilmington International on, say, Oct. 1, the tentative opening day Ior
the UNCW camp, will cost $275--plus Iuel surcharges and taxes--iI tickets are purchased at least 14 days in
advance.
OI course, you'll need some wheels to get Irom the airport to the campus. An outIit called Payless Rental Car oIIers
the cheapest rate in Wilmington, promising to put you behind the wheel oI a subcompact Ior only $27.89 a day. II
that's too much traveling Ior one day, the Wilmington Econo Lodge Intown has the best bargain, with rooms at iust
$40 a night.
Oh, there's one other thing Ians should know beIore departing Ior Wilmington: According to initial reports Irom
UNCW, all workouts at Camp Jordan "will be closed to the public."--Dave McKenna
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Exhibit 88
Buck Lo OrIgInuI ArLIcIe
RedskIns' TruInIng Cump AdmIssIon Churge: un N Trend?
AugusL o6, zooo CURTS ECHEBERGER BOOMBERG NEWS
ASHBURN, Vu.-AnILu und GuvIon Moomuw weren'L LhrIIIed when WushIngLon RedskIns owner DunIeI Snvder becume Lhe IIrsL Lo churge Iuns Lo wuLch summer
prucLIce.
TruInIng cump opened on Lhe Moomuws' qLh weddIng unnIversurv, so Lhev wenL unvwuv - IIIIed wILh skepLIcIsm und memorIes oI when Lhe RedskIns' summer
prucLIce provIded un InexpensIve ouLIng Ior Lhe IumIIv.

Thev IeIL udmILLIng LhuL u duv uL Lhe brund-new LruInIng compIex wus probubIv worLh Lhe prIce.
"There's noL u whoIe IoL LhuL's Iree unvmore," AnILu Moomuw suId. "We hud u nIce LIme."
Though munv cIubs suv Lhev wouIdn'L dreum oI runnIng Lhe rIsk oI embILLerIng Iuns Ior u IImILed umounL oI revenue, oLhers suv LhuL II Lhe RedskIns cun suLIsIv
peopIe IIke Lhe Moomuws und sLIII muke monev, Leums LhroughouL Lhe NuLIonuI ooLbuII eugue wIII quIckIv IoIIow suIL.
"Somebodv hud Lo go IIrsL," suId Deun Bonhum, presIdenL oI Lhe Bonhum Group, u Denver-bused sporLs-IrunchIse consuIL IIrm. "The RedskIns ure LukIng u bIg
rIsk wILh Lhe neguLIve pubIIcILv und possIbIe uIIenuLIon oI LheIr Iuns. I IL works Lhough, vou cun resL ussured IL wIII become u IeuguewIde Lrend overnIghL."
The Leum begun churgIng udmIssIon uILer Snvder puId $1 mIIIIon Lo breuk u conLrucL und move cump Lo Lhe WushIngLon suburb oI Ashburn, VIrgInIu, Irom Lhe
wesLern MurvIund Lown oI rosLburg.
L's one oI severuI drumuLIc chunges Lo u once-sLuId IrunchIse mude bv Snvder, who puId u record $8oo mIIIIon Lo buv Lhe Leum IusL veur.
The RedskIns opened cump JuIv zo, wILh un esLImuLed q,ooo Iuns uLLendIng Lhe mornIng und uILernoon prucLIces combIned.
$1o AdmIssIon
TIckeLs cosL $1o Ior uduILs und chIIdren over Lhe uge oI 1z. WILh LhuL, Iuns guIn udmIssIon Lo Lhe $z mIIIIon compIex oI prucLIce IIeIds und such Iun umenILIes us
u chIIdren's ucLIvILv ureu.
The RedskIns wouIdn'L dIscIose how much revenue Lhev expecL Lo generuLe durIng Lhe sIx weeks oI cump, uILhough Lhev suId Lhev hoped IL wouId puv Ior Lhe
LruInIng compIex.
TurnouL Lhe IIrsL week IeII shorL oI expecLuLIons. The IIrsL weekend prucLIce LhuL wus open Lo Lhe pubIIc drew ubouL 6,ooo Iuns, even Lhough sLuII wus prepured
Lo hundIe us munv us 1=,ooo.
"We beIIeve we've deIIvered Lremendous vuIue Lo Lhe Iuns here," Leum PresIdenL SLeve BuIduccI suId. "The kIds ure IuughIng und duncIng. ThIs Is u success."
ShorLIv uILer Lhe RedskIns dIscIosed LheIr InLenLIons oI churgIng udmIssIon Ior LruInIng cump, execuLIves Ior Lhe Super BowI chumpIon SL. ouIs Rums
uddressed Lhe Ideu, Loo.
"We LhoughL ubouL IL," suId Bob WuIIuce, Lhe Rums' generuI counseI. "We jusL wunLed Lo see whuL Lhe reucLIon wus In WushIngLon.
"I Lhev ure ubIe Lo murkeL LhIs und IL goes over weII, LhInk vou couId see IL deveIopIng InLo u Lrend. Teums ure uIwuvs IookIng Ior wuvs Lo generuLe uddILIonuI
revenue."
The RedskIns wIII seII LIckeLs Lo o prucLIces LhIs summer. The more Iuns uLLend, Lhe more Lhe Leum cun churge sponsors Lo dIspIuv bunners und
udverLIsemenLs uround Lhe IIeId, Loo.
The Leum uIso churges $1o Lo purk und seIIs Iood und RedskIns merchundIse: u hoL dog wus $=, u womun's Lunk Lop wus $o, und u men's coIored RedskIns
shIrL wus $;q..
Though Lhe prucLIce oI seIIIng uccess Lo LruInIng cump couId be even more IucruLIve - wILh Leums churgIng Iuns Lo wuLch vIdeoLuped workouLs on Lhe nLerneL or
Ior uuLogruphs or pIcLures wILh pIuvers, cheerIeuders und muscoLs - munv Leums deIend Lhe LrudILIonuI prucLIce oI mukIng workouLs Iree und open Lo Lhe
pubIIc.
"We don'L see cump us u revenue-generuLIng LooI," suId PILLsburgh SLeeIers spokesmun Ron WuhI. "We see IL us un opporLunILv Ior uII Lhe peopIe who cun'L geL
LIckeLs Ior Lhe reguIur seuson Lo come ouL und geL cIose und personuI wILh Lhe pIuvers."
The New SeuL Icense?

ThIs Isn'L Lhe IIrsL seemIngIv rogue revenue-generuLIng Ideu LhuL becume uccepLed.
When Lhe CuroIInu PunLhers IrunchIse wus uwurded In OcLober 1, Lhe cIub suId IL pIunned Lo seII Lhe rIghL Lo buv LIckeLs Lo ruIse revenue Ior u sLudIum.
Munv N owners sneered uL Lhe Ideu oI "personuI seuL IIcenses," whIch eIIecLIveIv requIre Iuns Lo puv LwIce Ior LIckeLs - once Ior Lhe rIghL Lo buv Lhem, Lhen Ior
Lhe LIckeLs LhemseIves.
ArL ModeII, owner oI Lhe CIeveIund Browns uL Lhe LIme, wus umong Lhem. " huve ubouL us much chunce oI seIIIng Lhem In CIeveIund us vou huve oI buIIdIng un
IgIoo. L wIII never huppen."
The PunLhers soId more Lhun 6o,ooo seuL IIcenses, generuLIng $11= mIIIIon Lowurd consLrucLIon oI LheIr $18= mIIIIon sLudIum.
The concepL IuLer wus used Lo generuLe monev Ior new sLudIums In SL. ouIs, OukIund, Tennessee, CIncInnuLI und PILLsburgh. ModeII moved hIs Leum Lo
BuILImore, und Lhe Ruvens' new sLudIum wus purLIuIIv Iunded bv Lhem, und Lhev were used Lo ruIse monev Ior Lhe new CIeveIund Browns' IIeId.
TruInIng cump udmIssIon mIghL be jusL u zooo versIon oI personuI seuL IIcenses.
"The RedskIns ure LukIng u bIg rIsk, buL Lhere Is un uwIuI IoL workIng In LheIr Iuvor, IncIudIng Lhe popuIurILv oI Lhe N und Lhe IncredIbIe uppeLILe oI sporLs
Iuns," Bonhum suId. " LhInk Lhere wIII be u hIgh IeveI oI InLeresL. ThIs couId reuIIv work."
As prucLIce begun, Lhe Moomuws, AnILu, 6, und GuvIon, ;z, oI AIexundrIu, VIrgInIu, suL In Lhe sLunds wuLchIng LheIr IuvorILe pIuvers und LuIkIng ubouL Lhe
Leum's poLenLIuI Ior Lhe upcomIng seuson. Thev were enjovIng LhemseIves.
"We've been RedskIns Iuns Ior mosL oI our IIves," AnILu Moomuw suId. "We LhoughL LhIs wouId be u greuL pIuce Lo ceIebruLe."
CopvrIghL zo11 os AngeIes TImes Terms oI ServIce PrIvucv PoIIcv ndex bv DuLe ndex bv Kevword

Exhibit 89

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Pay-per-view practice
Redskins charging fans to watch training camp

ASHBURN, Va. (AP) --
Washington Redskins receiver
Albert Connell shook his head
and chuckled when asked iI he
would pay $10 to watch himselI
practice.
"I don't know. I don't know,"
Connell said. "It'll be good to see
that support out there, we're going
to need it. But I don't know iI I'd
pay $10."
And that's iust the halI oI it -- it's also $10 to park -- but tens oI
thousands oI Ians apparently are willing to pay it. They'll start
arriving Thursday, when the Iull roster reports Ior the training camp,
and the Redskins become the Iirst NFL team to charge an admission
price Ior people to watch practice.
"I think we'll be close to capacity," said team president Steve
Baldacci, which means an opening day crowd approaching 7,500.
The decision to charge (people under 12, though, get in Iree) pushes
the proIessional sports envelope in the search Ior creative ways to
generate money -- a priority Ior the Redskins given that owner Dan
Snyder paid a record $800 million to buy the team last year and will
pay his players about $100 million in salary and bonuses this year.
The Redskins spent more than $2 million to prepare Ior the big
moment, altering the Redskins Park landscape to make room Ior
bleachers that hold 6,500. There's also an "NFL Experience" area
where Ians can test their throwing, running and kicking skills.
By all indications, the team
will turn a tidy proIit during
the Iour-week camp. In
addition to parking and
admission, Ians can buy
Click here for more on this story

Workers at the Redskins' camp busied
themselves Wednesday hanging banners to
greet die-hard fans willing to pay admission to
see the 'Skins practice. AP
Pay-Per-View
The cost a family of four, including a
teen-ager and a child under 12, would
likely pay if attending the Washington
Redskins' training camp at Redskins
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exclusive "training camp
2000" merchandise and
lunch to pass the time
between practices. A day at
camp could routinely cost a
Iamily oI Iour $100.
Baldacci has had a diIIicult
time iustiIying the
groundbreaking decision to
charge admission. At Iirst,
he said the charge was
comparable to that oI other teams. This week he said the Redskins are
"not the Iirst to charge," then qualiIied the remark by noting that
parking Iees are charged at San Francisco and at camps Ior "several
teams in the NFC East."
The Associatea Press surveyed all 31 NFL teams. No other team
charges admission Ior routine training camp practices, and only three
-- Indianapolis, San Francisco and the New York Giants -- have a
parking charge that is administered by the universities where the
camps are held.
Parking at the Giants' camp is next highest at $5, and a season pass is
$10, meaning that Ians can get into every Giants practice Ior the cost
oI one admission at Redskins Park. Jerry Jones has made a mint
selling corporate sponsorship tents in Dallas, but general admission to
the practices is Iree and Ians can enter the Cowboys' "NFL
Experience" area Ior a $1 donation to charity.
"Charging our Ians Ior admission or parking at training camp is
something that we have reiected," said Joe Banner, executive vice
president oI the Philadelphia Eagles. "We view our training camp,
Iirst and Ioremost, as an opportunity to give back to our Ians. ...It
gives many people who might not otherwise have an opportunity to
see the Eagles either due to the economics or the sold-out status oI
our games."
Baldacci says the games, souvenirs and Iood make a day with the
Redskins worth the money. Actually, the biggest draw might be the
talent on the Iield: Deion Sanders, Bruce Smith, Darrell Green and
others on a team considered a Super Bowl contender. It's hard to
imagine, Ior example, 7,000 paying to watch practice aIter the team
went 6-10 two years ago.
Market Iorces will determine whether the idea succeeds or Iails. In
past years, Ians drove three hours and stayed in hotels to watch
training camp when it was held in the Maryland mountains, so the
expense is not a barrier Ior many. Certainly, iI charging admission
turns out to be a big moneymaker Ior the Redskins, other teams are
sure to Iollow.
But is it value Ior money? Guard Keith Sims, who regularly pays $7
Park:
Parking: $10
Admission: $30 (kids 12 and under get
in free)
Food: $18 (three hamburgers, $5 each,
and one hot dog, $3)
Snacks: $4 (four bags of chips)
Drinks: $12 (four sodas)
Water: $8 (four bottles)
2 T-shirts: $39.98
2 "Training Camp 2000" caps: $47.98
Total: $169.96

to watch a movie, thinks it is.
"Part oI practice may be boring Ior the average Ian," Sims said. "But
they'll get a sense oI what we go through twice a day Ior this Iive-,
six-week period to get an opportunity to play the season."
Notes: The Redskins were hoping to wrap up negotiations with No. 3
overall draIt pick LaVar Arrington late Wednesday. ...No deal is
expected with running back Stephen Davis anytime soon. The two
sides haven't talked Ior three weeks.

Copvright 2003 Associatea Press. All rights reservea. This material
mav not be publishea. broaacast. rewritten. or reaistributea.
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Exhibit 90

Dan Snyders Bad-Luck Lottery The Redskins'
scratch-off game didn't work out, either
By Dave McKenna on June 25, 2010
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The Virginia Lottery recently scrapped Redskins Mania, a scratch-ticket program and the centerpiece of the first
cooperative gaming venture between the team and the state.
The endeavor was plagued by overpricing and unfulfilled promises. Only about a third of the tickets even got sold;
many bigger prizes, including two of three much-advertised $1 million giveaways, were never awarded. Similar
NFL lottery games have thrived, but the Redskins version never lived up to the hype. Itll be relaunched soon, with
a whole new game plan and a marketing pitch.
The Redskins lottery venture, in other words, has worked a lot like every other Redskins venture of the Dan
Snyder era.
Redskins Mania began in early 2009, after NFL owners voted to permit certain ties to state lotteries. The unanimous
vote was oddly timed: As scratcher permissions were granted, NFL lawyers were busily crushing a new Delaware
law that permitted Vegas-style sports betting. Its hard to suss out the NFLs stance here, to understand those
different positions, says Keith Whyte of the National Council on Problem Gambling. But the league won on both
counts: The U.S. Supreme Court last month let stand a lower-court ruling forbidding Delaware from opening its
voter-approved sports books. And shortly after the owners vote, scads of states began marketing NFL scratch-
ticket games. The New York Jets and Giants, New England Patriots, Green Bay Packers, Cleveland Browns, and
Tennessee Titans, among others, all sidled up to the table.
But none of them came onto the scene with more razzle-dazzle than the Redskins. The team introduced its lottery-
ticket campaign, billed as $50,000,000 Redskins Mania, at a Redskins Park press conference during which
Clinton Portis and Chris Cooley hammed it up with cheerleaders in front of the franchises three Vince Lombardi
trophies. Redskins Chief Operating Officer Mitch Gershman said the game offered lottery players a chance to win
once-in-a-lifetime Redskins experiences.
Next to [Albert] Haynesworth and DeAngelo Hall, this may be the most important investment that the team makes
this off-season, Gershman told the Washington Post. A year later, hes been proved right: Redskins Mania and the
Haynesworth acquisition worked out similarly. Gershman has since been booted out of his COO position.
According to the Virginia Lottery, 3.8 million Redskins Mania scratch tickets were printed up, with a $20 price tag
each. Thats expensive in the scratcher market: No other scratch ticket in the state, in fact, cost more. The Skins
ticket was also the most expensive of all the NFL scratch tickets in the first year of football lotteries. The next most
expensive among the class of 2009 was that of the Packers, sold through the Wisconsin Lottery. It cost $10. All the
other NFL teams offerings, even the scratcher from the Dallas Cowboys occasionally Snyderesque marketing
The Ravens ticket cost $5. The
Redskins cost $20. Guess whose sold
more.
squad, cost just $5.
Perhaps not coincidentally, most of the Redskins tickets went unsold. We sold about 37 percent of our tickets,
says Virginia Lottery spokesperson Jennifer Mullen. This was a new game, and we discovered a lot of things. We
discovered the $20 price point was a bit of a barrier.
Most of those sales came early. The teams disastrous on-field performance did little to increase demand once the
season started.But the plug couldnt just be pulled on Redskins Mania because the game had built-in second-
chance giveaways allowing losing players through March to send in their tickets to be eligible for other prizes. By
then, Mullen says, theyd seen a big dip in sales and decided to end the mania.
On May 28, Redskins Mania officially died. Most of the promised big giveaways still hadnt been awarded: As of
this week, along with two of the three $1 million prizes, three of the six $25,000 prizes and over 60 percent of the
$5,000 and $1,000 purses had not yet been handed out.
The number of actual giveaways lived up to original billing in only one Redskins Mania prize category, and it was a
noncash giveaway: Eight Redskins Mania players ended up winning season tickets for 20 years, just as advertised.
One guy claiming to be a winner of season tickets went onto a lottery players message board to tell folks who
didnt win Redskins Manias top noncash prize to count yourself lucky. [T]he extra taxes for winning 20 years
of tickets is going to kill me in the 2010 tax season, he wrote. He also said he bought more than 300 of the $20
tickets while trying to win.
Why the reduced giveaways? People running the lottery dont risk their own money. Because the expected number
of buyers didnt show up, the much-hyped number of winners didnt show up, either. Its not that theres
unclaimed money, Mullen says. Prizes are based on an estimation of sales, and having sold 37 percent of the
tickets, and one of the three [$1 million] prizes was claimed, so proportionally, that was correct.
Whatever caused the Redskins scratch ticket to flop, it wasnt the mediums fault. Other NFL scratch tickets did
just fine, thank you. Take the game being offered by the team just up the road, the Baltimore Ravens Cash Fantasy,
marketed through the Maryland Lottery. The state agency says it sold essentially every Ravens Cash Fantasy ticket
that was printed. All three of the $1 million top prizes were given away.
The Ravens scratch tickets cost only $5. One Maryland Lottery official, requesting anonymity, tells me the agency
and team were both surprised when the Redskins announced such an expensive ticket but briefly considered
following Washingtons lead. Ultimately, the official says, they concluded that people wouldnt buy them for
$20.
The Ravens and the Maryland Lottery announced last week that the 2009 Cash Fantasy game holds the distinction
of being the best-selling $5 scratch-off ever sold by the Maryland Lottery. So the lottery game offered by the
Ravens, one of the most stable franchises in the NFL over the past decade, will come back basically unchanged for
the 2010 season, with the same $5 price and three $1 million prizes.
The Redskins, of course, have had the least stable operation in the NFL, on and off the field, since Snyder came
here in 1999. So it makes metaphorical sense that the teams initial lottery offering is getting blown up after its one
disastrous season. Though nothings been announced by the Redskins or the Virginia Lottery, the name and huge
price point of the 2009 venture are gone; current plans hold that the team will market a scratcher called Redskins
Legacy beginning in August.
Given Snyders reliance on all things pre-Snyder, dont be surprised if images from Joe Gibbs I and The Future Is
Now era of Redskins history are used to sell the game. Tickets will cost $10.
Read Cheap Seats Daily every weekday morning at washingtoncitypaper.com/blogs/citydesk.

Exhibit 91

Seats of Power: A Return to Skybox
Lobbying?
By Jeffrey H. Birnbaum
Wednesday, May 14, 2008
Not long ago, lobbyists regularly entertained lawmakers and their
aides in skyboxes at local sports arenas. But after a series of
scandals on Capitol Hill, the law was changed to forbid
congressional officials from accepting anything of value from
lobbyists without repayment -- let alone the best seats in the
house.
Now the Washington Redskins are talking up a new twist. Their
sales force has given a one-page handout to a potential customer that states that congressional officials could accept
a free "Suite Guest Pass" to a skybox as long as they have a ticket for anywhere else in the stadium, including a $25
standing-room-only ticket.
The document, a copy of which was obtained by The Post, says that such guest passes allow for only a "short visit."
It does not define "short visit" or say who would monitor the requirement.
Several ethics experts and top lobbying managers said they would at a minimum advise caution. "This doesn't
sound kosher to me," said Jan W. Baran, an ethics expert at the law firm Wiley Rein. He said he thought it could be
seen as a "gimmick" in which a guest could "buy a standing-room-only ticket for $25 and then accept from the
lobbyist a free guest pass to the suite."
David Donovan, the Redskins' general counsel, said that the document was not legal advice and that it was intended
simply to provide information to customers who had asked about the impact of the new lobbying rules. He said the
team was merely repeating what it had been told by government ethics offices.
"All we're trying to tell people is what is required to comply with the rules, not how to get around them," Donovan
said. Referring to the team's statements about the pass, he said, "The operative words are 'to drop by for a short
visit.' "
"If they [lawmakers and staffers] want to stop by for more than a short visit," he added, "they're doing something
we're not suggesting."
Redskins spokesman Karl Swanson confirmed that the document had been given to a potential customer. He said
the document was used by the team's sales force as "a talk sheet" to provide answers when a customer asked about
government ethics rules and their impact on the suites. He said that the sales staff used the document in
conversations with customers fewer than 10 times in the past year and a half.
Headlined "Government Ethics Rules re: Suite Tickets," the document notes that "Government officials/employees
can accept invitations to your Suite" through "Suite Guest Passes."
"These passes allow recipients who already have a ticket to the game to drop by an Executive Level Suite for a
short visit," the document reads.
"If you are a lobbyist (or your company employs lobbyists), a House/Senate employee to whom you give a game

Page 1 of 3 Seats of Power: A Return to Skybox Lobbying?
6/1/2011 http://www.washingtonpost.com/wp-dyn/content/article/2008/05/13/AR2008051303040_pf.html
ticket and a Suite Guest Pass would be required to reimburse for the face value of the game ticket and could accept
the Suite Guest Pass," the document says. "If you are not a lobbyist, then a House/Senate employee can accept a
game ticket valued at less than $50 and a Suite Guest Pass for free."
The next paragraph states: "Limited View/standing room only Tickets: These tickets cost $25. A government
employee who bought such a ticket from the Redskins could accept a Suite Guest Pass (referenced above) from you
to visit your suite without reimbursing you."
The document concludes with a caveat in small print at the bottom of the page: "The foregoing is provided for
informational purposes only. The Washington Redskins cannot provide you with legal advice. Please consult your
legal advisor with respect to these rules or their application to your own situation, or call one of the government
ethics offices." It then lists the two congressional ethics committees and the U.S. Office of Government Ethics and
their phone numbers.
Donovan told The Post that the team had cleared its approach with government ethics officials. After being
contacted by The Post, he said, the Redskins again telephoned the Office of Government Ethics and confirmed that
a "short visit" was not improper. A spokesman for the office declined to comment, citing its policy to not talk to the
press for publication.
Some of the capital's top ethics experts, who regularly counsel lawmakers and corporations, are not convinced that
a free pass to a skybox, even if only for a short visit, is acceptable under the new law for congressional officials.
"The pass being offered is a benefit by definition, and it comes under the gift rule, whether the stay is long or
short," said Robert Bauer, chairman of the political law group of the law firm Perkins Coie. "It may be a larger or
smaller gift, but it certainly would seem to be a gift all the same. So I would think hard before accepting the offer."
Kenneth A. Gross, a lobbying law expert at Skadden, Arps, Slate, Meagher & Flom, said the pass cannot be
considered free for the purposes of the lobbying law. "It is difficult to say that a suite pass has no value, and it
would have to be dealt with under the ethics rules," he said. "I don't know what kind of valuation you can put on it -
- maybe the highest ticket price in the arena -- but it's not free."
Top lobbying managers in Washington also said they would steer clear of the free passes. Asked if he would use
them to entertain congressional aides, J. Steven Hart, chairman of Williams & Jensen, said, "absolutely not." Joel
Jankowsky, who heads the lobbying practice at Akin Gump Strauss Hauer & Feld, said he would be "wary."
The ethics law, enacted last year, stiffened the rules governing gifts to lawmakers and their staffers. Lobbyists and
entities that employ lobbyists are generally prohibited from giving anything of value to members of Congress and
their aides. Organizations that do not lobby can give to these same people benefits worth less than $50, but no
more.
In addition, penalties for violations of the lobbying laws were stiffened. Companies, trade associations and unions
must certify under oath twice a year to the government that they have made no improper gifts. Making a false
certification would potentially subject violators to both civil and criminal penalties, including up to five years'
imprisonment.
The new ethics rules were brought about partly in reaction to abuses by the now-jailed lobbyist Jack Abramoff.
Before his downfall in 2004, Abramoff spent about $1 million annually in funds largely provided by his clients to
lease four skyboxes -- two at FedEx Field and one each at Oriole Park at Camden Yards and what is now the
Verizon Center. He kept them filled with lawmakers, staffers and their guests, part of a multimillion-dollar
congressional care-and-feeding project that came under heavy criticism by colleagues and prosecutors. Abramoff
pleaded guilty to fraud, tax evasion and conspiracy to bribe public officials in 2006.
FedEx Field, the Redskins' stadium in Maryland, has about 250 skybox suites. The suites, which are enclosed and
heated and have excellent views of the playing field, offer many amenities, including televisions, comfortable
chairs and private bathrooms, and they often have food and drink delivered. By contrast, parts of the standing-
room-only section have an obscured view of the field, although televisions allow patrons to see the game, Swanson
said.
Baran said anyone visiting a suite from the standing-room-only section would surely be tempted to stay a while. As
for the team's short-stay exception, he added, "Who will oversee this, the Redskins' police?"

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Exhibit 92

Dan Snyder Charges Redskins Fans a 20% Tax!
Posted by Dave McKenna on Aug. 5, 2010 at 10:46 am
Crafty Bastards
Search
Contests & Free
Stuff
Win advance
screening passes to
see Friends with
Benefits Win tickets
to Rock of Ages Win
advance screening
passes to see
Transformers: Dark
of the Moon Win
Be Laughter 4 Win
Wind & Fire Win
tickets to see The
Glitch Mob
Events
Street Box
Named Desire
Opening
Reception DC
Jazz Festival:
Jazz in the
'Hoods June 1-
13
Promotions
The fun and service-oriented folks at MisterIrrelevant (yeah, the
same geniuses who gave us the Bob and Rob Drinking Game) informed readers about an appropriate-for-the-
immature-football-fan-of-any-age item being sold at Dan Snyder's store at Redskins.com. It's a doll of Cleatus the
Robot, the animated mechanical thingee that stomps onto your screen every several seconds during Fox's football
broadcasts, painted in the home colors.
Redskins.com charges $30 plus shipping for the product.
The same doll is also sold through the online store at the Fox Sports website. But the network retails its identical
burgundy-and-gold mini-dude for just $24.95.
That's a difference of $5.05.
We already knew Dan Snyder's ownership was taxing on the fans who pay his bills. But this is ridiculous.
The Snyder tax in this case is 20 1/4 percent.
Remember that the next time Redskins Park puts out a press release about Snyder's charitable deeds.

cheap seats daily, cleatus the robot, Dan Snyder, foxsports, Sports, Washington Redskins

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Exhibit 93
The Redskins Store Actually Sells This
By Jamie Mottram | August 4, 2010
We could do an entire series of posts like this. In fact, we probably will. First up, the Redskins store actually sells a Redskins Cleatus Robot
action figure for $30. Its even a featured item on the stores homepage.

If you havent clawed your eyes out yet, heres the description:
The NFL Fox Sports Robot marked the beginning of a new era for Americas favorite spectator sport. This 10 inch poseable
PVC plastic Redskins Cleatus Robot action figure features the highest quality and greatest attention to detail available in an
action figure. Cleatus the FOX Sports Robot utilizes his fully articulating joints to evade defenders and score touchdowns. A
must-have piece for every sport fanatics collection.
The Robot definitely marked a new era. An era of annoying the shit out of everyone who has to watch the NFL on Fox.
Now, it does seem that a Cleatus Robot is made for every NFL team, so maybe the Redskins should get a pass. The Skins, however, are the
only NFC East team to actually feature it on their website.
Theres a reason Dan Snyder makes a dollar and a cent in this business.
Topics: Redskins, Snyder Sucks | 12 Comments
12 Responses to The Redskins Store Actually Sells This
1. Dustin Fox Says:
August 4th, 2010 at 4:53 PM
Thank You! I generally have a large gathering of friends for every Skins game. Never fails one of my buddies will say they like the
robot. And I go apeshit crazy! What could you possibly like about a robot doing Deions dance? Unless you are a child or wife, your
not allowed to like the fargin robot.
2. peteywheatstraw Says:
August 4th, 2010 at 4:56 PM
Cleatus is based on Marcus Washington I think, so it kinda makes sense.
3. TWW Says:

Exhibit 94
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Re: candidates to succeed Gibbs, I expect Snyder to seriously consider assistant head coach Gregg Williams. But it's
also likely Snyder will inquire about Bill Cowher, who spent the year in the CBS studio and has told friends he
definitely will do the same in 2008 while his youngest daughter completes high school in North Carolina. It'll be
interesting to see if Snyder will try to use his millions to change Cowher's mind.
BOBBY LIKES GARRARD. From Bobby B of Santa Fe, N.M.: "Thanks for the piece on the Jags and David Garrard. They
are a team that you might not be a fan of but you can't help but root for. Garrard is like that. When I see him in
interviews he seems like such a quiet unassuming guy. His demeanor is nothing like what you generally expect from
an NFL quarterback. His anecdote about the quarterback draw call was interesting to me: with the success of Peyton
Manning and to a (not much) lesser degree, Tom Brady, do you think we'll go back to letting quarterbacks call their
own plays?''
Garrard didn't call that play, though obviously he wanted to. I don't think we'll see quarterbacks call their own plays in
the foreseeable future, because coaches in the press box and on the sidelines see more, collectively, than the
quarterback can see, particularly with Polaroids before every snap showing formations and defensive trends.
BRUNO DOESN'T LIKE TOMLIN. From Bruno of Long Branch, N.J.: "The third-and-6 QB run by Pittsburgh in the fourth
quarter was the most gutless call in recent playoff memory. Mike Tomlin showed no faith in Ben Roethlisberger or his
offense and they deserved to lose for making such a call, not to mention that he got a do-over on the two-point
conversion call and still goes for it from the 12-yard line. Why is this guy a head coach?''
He's a damn good head coach and the Steelers are fortunate to have him. Yes, going for two from the 12 was a
brainlock call. And I assume Bruce Arians, the offensive coordinator, called the end sweep by Big Ben. I didn't like that
call either. Two points: left tackle Trai Essex blocked air instead of a Jaguar, and his was the key block on this play. If
he doesn't make the block, the play surely fails. I agree, though, that they should have thrown the ball.
I WONDER IF SEAN'S A STEELER FAN. From Sean Pritchard of Cleveland: "Hi Peter. I love your work and respect the
hard work you put into your columns. However, I wanted to chime in on the "hole" Garrard had to run through on
fourth-and-2. I would bet you have access to NFL films. Check the replay on Casey Hampton. No one pancakes
someone who is five-foot-10 and 320 pounds. He was tackled to the ground, as was Larry Foote. Garrard only made it
since the refs put their whistles in their pockets for this game. The bigger issue, is what should the NFL do to correct
the atrocious calls by the referees this year?''
Officiating czar Mike Pereira has stressed to officials that they've got to visually see holding, not just what appears to
be holding, in order to make the call. Did you see Hampton being held and wrestled to the ground? Or did you see
Hampton falling to the ground and you assumed it was a hold? I have watched the replay several times, not from
coach's tape but from TV replays, and I don't see a hold. I'm not saying there wasn't a hold, but I didn't see it.
ANYONE OUT THERE HAVE A NON-STEELER QUESTION? From Rob Parker, of Saddle Brook, N.J.: "I consistently hear
people say how much better Ben Roethlisberger is this year, but I never hear anyone mention his new quarterback
coach, Ken Anderson. Being a lifelong Bengals fan (suffering), it kills me to see Anderson on the Steeler sideline, but I
would think he had a lot to do with it.''
Anderson's a good man and a good technical coach. Good observation, Rob.
WHY DO COACHES INTERVIEW FOR HEAD COACHING JOBS? From Herbert Kay, of Manhattan Beach, Calif.: "You have
never given an explanation why it is necessary to interview for a head-coaching job. It is not as if there is not a body
of work out there to judge candidates by. It is a lot like combines. Why have scouting combines if you have game
film? Biggest waste of time imaginable.''
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Joe Gibbs will announce his retirement this afternoon for the second time as coach of the Washington Redskins. It's a
family decision as much as a football decision. Gibbs' three-year-old grandson, Taylor, is being treated for leukemia,
and Gibbs has been torn about the time requirements of football versus family over the past year.
I spent 30 minutes with Gibbs during an NBC interview last Thursday, focusing mostly on the impact of Sean Taylor's
death. And I can tell you that the decision to retire -- made late Monday night after a long meeting with owner Daniel
Snyder -- had to have been extremely difficult.
Gibbs really likes the team he assembled. He'd finally imported the right mix of veterans (linebacker London Fletcher,
a maturing corner in Fred Smoot, guard Pete Kendall) to go with a smart old quarterback ( Todd Collins) and a young
quarterback ( Jason Campbell) he thought he could win with. "Sometimes you have to coach a team hard,'' he told
me, "and sometimes a team just sort of coaches itself. This team is playing for Sean right now, and playing hard every
day. I love this team because it has taken on such a mature attitude. The guys just don't want to let each other
down.''
The team could have splintered in the wake of the horrible loss to Buffalo in Week 13 -- made worse, obviously, by
Gibbs' decision to call a second straight timeout on the decisive field-goal try by the Bills, resulting in a 15-yard
penalty. But all Gibbs felt in the aftermath of that was support from his players.
They buried Taylor the next day, and three days later started their highly improbable four-game winning streak and
run to a wild-card playoff spot. The season ended with a 35-14 loss in Seattle on Saturday. The fact that the Redskins
stayed together was a tribute to two things -- the players' drive to win for Taylor and his family foremost, and the
players' respect for Gibbs
Gibbs admitted he learned a lot from the blown call against Buffalo. A deeply religious man, Gibbs admitted he'd been
trying to sound convincing that he was coaching because God had told him to. Now he admitted that maybe he'd been
a little selfish in coaching because it was because he wanted to do it, not because God wanted him to do it. And he
determined after that game -- his explanation to me -- that he now would truly put his life in God's hands. I tell you
this story because I believe Gibbs, in all likelihood, prayed about what to do, and there's a good chance the answer to
his prayer was that God was telling him it was time to be with his family.
We don't write things like this very often in this business. But devout people say and feel devout things and are driven
by their relationship with their God. I think Gibbs is one of those people. And I think it had something to do with his
decision to retire.
I anticipate Gibbs will take time with his family now and return to the family business in North Carolina -- Joe Gibbs
Racing, winner of three NASCAR championships. He'll be able to control his fate there more than he could in his
second go-round in football.
Gibbs was 140-65 in his first run as Redskin coach, when the franchise won three Super Bowls. His 31-36 record in his
second tenure, over four seasons, ended with a 1-2 playoff record. It's sad that his second time around wasn't as
great as the first, and I thought he'd do better.
What he has done, I believe, is make Snyder focus more on the long-term solution and less on the quick free-agency,
big-money fix. And if you're a Redskins fan, I think that's an important thing to realize when you ask yourself whether
the second coming of Gibbs was worth it. I think it was, even if the record suggests otherwise.

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Are you telling me that without talking to a coach face-to-face that you'd put the future of your organization and the
hopes of your team's fans in his hands? It seems like Business 101, and Sports 101, that you'd interview a coach
before handing him your football team.
GOOD POINT, JAMES. From James Sweet, of Rochester, N.Y.: "I'm not sure how much (if at all) you should beat
yourself up over the relatively low rankings of Adrian Peterson, Fred Taylor, Marion Barber in your preseason top 500.
Over the last few years, I feel it has become apparent that it's all about the O-line. Not to take away from these guys
at all, but I'm not convinced there aren't half a dozen guys in just about every draft class who could achieve the same
thing given the right linemen blocking for them under the right scheme.''
Couldn't have said it better. But Peterson, in particular, is the kind of difference-maker I wish I'd recognized in August.
DONNIE BRASCO GETS SOME WELL-DESERVED PUB. From Gilbert Medrano, of Houston: " Don Banks mentioned a 12-
team playoff format for the postseason that ignores a team's conference. It seems like an interesting idea to me,
which could make for better matchups in the Super Bowl. What are your thoughts and would it ever be possible?''
I love the idea. Don's right. We barely recognize the difference between conferences this year, and imagine the fun if
a playoff matchup in the wild-card round wasn't a rerun of Washington- Seattle from two years ago but rather
Washington- San Diego or Jacksonville-Tampa Bay? I think it's something the league should consider, but it won't
because too many veterans inside the league want to keep the AFC-NFC "history'' alive.
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against Joe Gibbs Racing Wednesday were swift and... - August 21, 2008
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Gibbs' second act in Washington... - January 08, 2008

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PUBLISHED 5 months and 6 days ago
LAST UPDATED 5 months and 6 days ago

Dennis Dillon Sporting News
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It can be hell trying to replace a Hall of Fame coach. If you don't believe it, just look at the men who followed in Joe Gibbs' footsteps after he retired as Redskins coach following the 1992
season.
Richie Petitbon: 4-12 in one season.
Norv Turner: 50-60-1 in almost seven full seasons.
Terry Robiskie: 1-2 as an interim coach.
Marty Schottenheimer: 8-8 in one season.
Steve Spurrier: 12-20 in two seasons.
When Gibbs coached Washington from 1981-92, the Redskins went 140-65, reached the playoffs eight out of 12 years and went to four Super Bowls, winning three. Under the five coaches who
succeeded Gibbs, the Redskins were 75-102-1 and went to the playoffs once in 11 years.
Yes, it can be hell trying to replace Joe Gibbs. For gosh sakes, not even the man himself could do it.
The Joe Gibbs II era in Washington ended Tuesday afternoon, when Gibbs announced he was retiring -- again -- after four seasons and a 31-36 record, including 1-2 in the playoffs. That brings
to four the number of NFL head-coaching vacancies. Atlanta's Bobby Petrino resigned with three games left in the season, and Baltimore's Brian Billick and Miami's Cam Cameron were fired
last week.
A serious family matter weighed heavily on Gibbs' decision to step down; his 3-year-old grandson, Taylor, is being treated for leukemia. Gibbs, who likes to affectionately refer to his
"grandbabies," made an overnight trip to North Carolina on Sunday, a day after the Redskins lost to Seattle in a NFC wild-card game, to be with his family.
When Gibbs returned Monday, team owner Daniel Snyder tried to persuade him to stay on during a conversation that reportedly extended to 2:30 a.m. Tuesday. But Gibbs turned down the
overture.
"My family situation being what it is right now, I told him I couldn't make the kind of commitment I needed to make," Gibbs said at a press conference.
Would Gibbs, 67, have come back for another season if it weren't for the family crisis? I don't know the answer to that question. But I do know coaching in the NFL wasn't as fun for Gibbs the
second time around. I wouldn't say the game passed him by -- that would be ridiculous -- but it certainly changed during his absence, most of which he spent in the NASCAR arena as owner of
Joe Gibbs Racing.
"It's hard to go back," said former NFL offensive line coach Jim Hanifan, who coached with and under Gibbs in St. Louis, San Diego and Washington and remains a close friend. "It's like going
to a vacation spot you used to go to when you were a kid. Years later when you go back, it's not anything like we remembered it to be."
The game's parameters changed while Gibbs was gone. Free agency altered the landscape. No longer were coaches able to keep their best players for a long term, as Gibbs did during much of
the Redskins' run to three Super Bowl championships. Defenses caught up to offenses with their zone blitzes and other strategies. Gibbs tried to build his offense around quarterback Mark
Brunell, who was nearing the end of his career.
This past season was Gibbs' most difficult. The Redskins lost safety Sean Taylor to a fatal shooting in late November, a rules faux pas by Gibbs contributed to a loss to Buffalo that same week,
and then the team flew to Miami the day after that game to attend Taylor's funeral.
The team rallied to win its final four games and clinch the NFC's final playoff spot -- a testament to both the players and Gibbs -- but the season took an emotional toll on everyone.
Gibbs leaves with one year left on the five-year, $27.5 million contract he signed to return as Redskins coach. He will remain with the team as an advisor to Snyder.
Among the candidates who could replace him are defensive coordinator Gregg Williams, who would be a particularly popular choice among the players; offensive coordinator Al Saunders or
former Steelers coach Bill Cowher.
Here's the unique thing that separates Gibbs, inducted into the Pro Football Hall of Fame in 1996, from other NFL head coaches. He won Super Bowls with three different quarterbacks -- Joe
Theismann (Super Bowl 17), Doug Williams (SB 22) and Mark Rypien (SB 26).
"That's really his big-time legacy," Hanifan said. "That tells you something about the man."
That Gibbs is leaving coaching to spend much-needed time with his family, children and grandchildren tells me even more about Joe Gibbs.
Dennis Dillon is a senior writer for Sporting News. E-mail him at ddillon@sportingnews.com.
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The Al Saunders Playbook
This item appeared in Sunday's paper. Due to an odd quirk, however, it
never appeared anywhere on my blog. Go figure. Here it is, in slightly
elongated form.
One of the enduring punch lines of last year's 5-1 Redskins campaign
centered on Al Saunders and his fabled 700-page playbook, the "War
and Peace" of the NFL, minus the Russian winters. So after the coach's
40-minute media briefing ended Saturday afternoon, Saunders was
asked just how many pages were in this year's book. Simple question,
right?

What followed was a 30-minute
discourse, ranging from offensive
philosophy, route-running and
trickery to the nature of learning
and the meaning of language. The
meaty playbook, Saunders initially
explained, may contain about
1,800 plays, but it is less a strict
dictionary than a guide to the art
of offensive football.
"It's like a textbook," he began.
"Remember when you had an algebra textbook and it had all the tests in
it, and how to figure out all the equations, and how to figure out all the
formulas? Well, that's what the text of the [playbook] is."
Saunders further explained that using playbook thickness as a guide to
offensive complexity was a false pursuit. The numerical system assigned
to each wide receiver's routes, for example, allows for 999 different pass
patterns to be understood within a matter of minutes. Each number
corresponds to one of the three wide receivers.
"I could teach any one of you in 20 minutes," he told a group of seven
reporters, few of whom resembled a typical NFL wide receiver, possibly
excluding Wes Welker. "If you can count from zero to nine, you can be a
wide receiver in our offense."
The numbers, you see, are a stand-in for language. Instead of
memorizing "blue car shampoo," a receiver can be guided by this
football-for-dummies code. And Saunders proceeded to tutor David Elfin
of the The Washington Times, running through the basics of a dozen
potential routes by their numbers and directions. He then proclaimed
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Elfin ready to take the field.
"If you're signing him, I'm holding out of camp," Triple X ESPN Radio's
Bram Weinstein said.
"I'm more reliable," Elfin protested.
"Yeah, you might be, but I'm a gamebreaker," Weinstein countered.
"This is why it just cracks me up when all you guys make fun of that
playbook, okay?" Saunders said. "Kurt Warner could come and stand in
there today and call every play that we run, and know -- on probably 90
percent of them -- what to do. You know, '844' is always '844.' People
talk about the 700-page playbook all the time; in actuality, it could be
8,000 pages, you know? What it is, it's a reference for those guys. It's a
teaching tool. After the preseason, they don't have that any more. It's
done...."
"It's like English," Saunders continued. "You think it's a pretty simple
language -- unless you have a grammar teacher like I did -- but if you go
to France and you have to sit down in a restaurant and order a
hamburger and fries and ketchup. You can go back in the kitchen and
you can make it. But you can't order it if you don't know how to say it,
and therein lies the problem." He paused. "Whether you're allergic to
shellfish or not, that's something else."
Finally, Joe Gibbs emerged onto a Redskins Park balcony.
"I need to ask you one question," he called down to Saunders. Gibbs
looked at the media crowd. "I'll ask you a question that makes sense," he
promised.
Anyhow, Saunders's serious argument was that, outside of the
quarterback position, the complexity of his offense results neither from
encyclopedic length nor tomfoolery, but instead from taking proper
advantage of formations and shifts and matchups. Opponents "think it's
difficult," Saunders said; "we think it's easy."
So easy, evidently, that a blogger could employ this information to great
damage. After the talk ended, a team spokesman pulled me aside and
asked me not to give away the state secrets. Meanwhile, I was just
thinking about how if I ran a football team, we would call nothing but
"187" and "911."
(And yes, I did ask again just how many pages are actually in the
playbook. "I don't know," Saunders said. "I don't count 'em.")
By Dan Steinberg | July 30, 2007; 10:06 AM ET
Categories: Redskins

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In NFL, the playbook is sacred
Every playbook is different, but the key for every player is to sort through the clutter and learn
as quickly as possible, writes Liz Merrill.
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Originally Published: August 29, 2007

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By Elizabeth Merrill
ESPN.com
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It was hot, he was tired, and all a strapping, anonymous lineman -- we'll call him Joe Rookie -- wanted was a
Recommend
moment of privacy in the bathroom. He had done everything his coaches asked. He lugged his three-ring playbook
around like it was a Bible. He read it, knew it, and protected it enough to carry it into the stall, next to the toilet.
But this was Vikings camp, and the easiest way to haze a rookie was to play on his basest fear. Nobody knew what
happened to a rook who lost his playbook. Nobody wanted to know.
So Joe had barely dropped his pants when a group of veteran pranksters pulled a grab-and-dash.
Ross Dettman for
ESPN.comChiefs running back Michael Bennett shows off his offensive playbook. Under former coordinator Al
Saunders, Kansas City's offensive playbook was 700 pages.
"He laid it down, and they snatched it," said Michael Bennett, a former Vikings running back who is now with the
Chiefs. "He got up and took off running after those guys with his pants down."
In the NFL, the playbook is a sacred hardbound diary of trust. It's an accumulation of decades' worth of knowledge,
tweaked and perfected, sectioned off by scribbles and colored tabs. It's the first thing the fresh meat get when
preseason workouts start in the spring and the last thing that is pried from a player's sweaty mitts when The Turk
arrives and utters those dreaded 11 words.
Coach wants to see you in his office. Bring your playbook.
No two playbooks are alike. Some are as massive as 800 pages; others are thinner than the Mankato, Minn., phone
book. No layman or superfan could get through the first section without being completely confused. But therein lies
the trick, to sort through the clutter, learn fast and play faster.
"To me, playbooks are like going to a Chinese restaurant," Chiefs coach Herm Edwards said. "It's a big menu. OK,
what do you like, do you like poultry, do you like fish, do you like meat? We have all these things in this book
which you need to have, but at the end, this is what we are.
"You couldn't run all the things you have in the playbook. You've got no shot."
In Mankato, where the Vikings' hazing has subsided a little, Chad Greenway knows this. But he runs in the
sweltering heat with his playbook almost always within reach. To a young football player, the playbook is a
tangible sign that he's arrived in the NFL, a thick business card with his name, jersey number and the logo of his
new team.
Greenway grips it and guards it, knowing by Week 15, the NFL will have much of it figured out.
"[But] there's little things we do differently, and we don't want other people to know," Greenway said.
"So you always have it with you. That's the one thing that's sacred to football. It has all our secrets."
Ross Dettman for
ESPN.comVikings linebacker Chad Greenway, studying at training camp, says the playbook is the "one thing that's
sacred to football. It has all our secrets."
Details, details

Al Saunders is a jogging 60-year-old workaholic who has been known to leave reporters voice mails at 2 o'clock in
the morning, just to make sure he calls you back, just because he is still in another office working.
Before Saunders was scribbling plays on restaurant napkins, he was a teacher. He got his master's degree in
education at Stanford, and learned that most times, it's easier just to write everything down. That way there are no
mistakes, no misunderstandings.
"I've always tried to be really thorough," Saunders said.
When he became the offensive coordinator in Washington last year, commanding a three-year, $6 million salary,
Saunders caught some heat for the complexity of his 700-page playbook. Critics said it was too hard for the average
football player to digest.
Truth be told, the size estimates were inaccurate.
"If you took all of Al's playbook, it's a hell of a lot more than 700 or 800 pages," said Dick Vermeil, who won a
Super Bowl with Saunders in St. Louis and racked up offensive records in Kansas City. "But it's not all in [the
players'] book.
"It's the best I've ever seen. And anyone who's ever seen it says it's the best they've ever seen."
With Vermeil and Saunders, the Chiefs were never in need of bedtime reading. They'd get a smaller binder at the
start of offseason workouts, another one during minicamp, then a fatter playbook during training camp. Each day,
as they installed more plays, the book got bigger. Each week during the season, players received another book full
of plays they would run against that Sunday's opponent.
It seems almost strange that Saunders got his start under Don Coryell, a coach who didn't even have a playbook.
Saunders says his playbook is more of a textbook, a detailed explanation of a player's job complete with graphics,
X's and O's, and simplified text.
"There is not enough time in meeting rooms or on the field to teach everything a player needs to know," Saunders
said. "The reason our playbook is so thorough is because I feel that's the best way to teach a complex offense."
Some players grasp the complexities much faster than others. Redskins backup quarterback Todd Collins, an honors
student at Michigan, was called "Rain Man" by his teammates in Kansas City because he almost effortlessly knew
the book forward and backward. Damon Huard, another backup, learned it the hard way, by scribbling classroom
notes inside his playbook.
Ross Dettman for
ESPN.comChiefs running back
Michael Bennett lugs his
playbook almost everywhere
he goes during training camp.
The good news is that a player doesn't have to know every position on the field. But it does have a tendency to help.
"Marshall Faulk was one of the most studious players in a position other than a quarterback that I've been around,"
Saunders said. "And his play reflected that.
"But [players] don't have to memorize all 700, 800 pages of this thing. They'll learn what their position is required
to do on each play, and it's very detailed."
So detailed that inevitably, some players will lose interest. Saunders has toyed with the idea of putting $100 bills in
the middle of his playbooks. If the money is gone when the books come back, he'll know they've been used.
Learning curves

A gaggle of purple has gathered across the street from the Vikings' practice field, screaming for Bobby Wade and
Matt Birk as they try to slip into their dorm rooms for an afternoon nap.
Wade and Birk are complete opposites, from their size -- Wade is 186 pounds dripping wet; Birk comes in at 308 --
to their struggles in camp. Birk is a Harvard graduate whose giant feet are firmly planted in Minnesota. He knew
the old Vikings playbook inside out, and was intrigued when coach Brad Childress came last year with the West
Coast offense. Birk spent his spare time studying the intricacies of the playbook, and can tell any one of his
linemates where he needs to be.
"It is a very cerebral game," Birk said. "We spend hours and hours in meetings every single day.
"This is my 10th year in the league, and I still take my playbook home. Because the defenses are always changing,
too. They're always giving different looks. It's kind of like a cat-and-mouse game between the offense and defense.
That's why football, I think, is a great game. Very few guys can get by on just talent."
Wade knows this. But he's been the poster boy of NFL instability. He's on his fifth offensive coordinator in five
years, a victim of coaching changes and shuffles from Chicago to Tennessee to Minnesota. Five years, five different
playbooks. As a receiver, the best way for him to get on the field is to play full speed, to react, not think. Five
summers, and all he's done is think.
The concepts are similar, Wade says. Open any NFL playbook, and the formations, runs and passes are just about
the same thing.
Win McNamee/Getty ImagesTo know if
his playbooks had been read by players,
longtime offensive coordinator Al
Saunders once toyed with the idea of
putting $100 bills in the middle of them.
But the terminology is completely different.
In Tennessee, a play called Omaha was a deep route. In Minnesota, it's a short, quick, 6-yard out.
"If you mess that up," Wade said, "you're completely blowing the play."
Learn one section, and then the playbook gets fatter with every new installation. By Day 7 in Mankato, the Vikings
were still adding plays.
Wade has learned to prioritize in his study habits, nailing the plays that pertain to him the most first. Repetition is
the best way to learn. He needs to hear the quarterback call it, hear himself say it over and over in film study, see it
a couple of times on paper. That's the only way he can break himself of the old garble.
Complicating matters is the fact that he's learning three different receiver positions.
"I don't know about stressed out," Wade said. "But you definitely go through stages of what I call brain farts. You
feel like you know it so well that you kind of pull back on studying the way you would study, then something pops
up on you and you completely forget where you need to be."
Wade lugs his playbook just about everywhere, in his bag, just like Bennett does in Kansas City. Bennett had a
similar problem going from the Vikings' offense to New Orleans to the Chiefs in the span of less than a year. He
says it takes about two years for him to feel as if he really has a playbook figured out.
NFL X's and O's

AP Photo/Nati HarnikVikings
receiver Bobby Wade, with
Minnesota coach Brad
Childress, studies his playbook
during "any break that's not a
sleep break."
Want to know what's included in an NFL playbook? Here are 10 pages from the Arizona Cardinals' 2004
offensive and defensive playbooks obtained by ESPN.com. PDF large file
Wade's never had the luxury of two years.
"Any break that's not a sleep break, I just try to get into it," Wade said. "That's the biggest thing younger guys don't
understand. Everybody's going to be able to compete physically. It's going to come down to what your mental
capacity can hold and how long you can hold it for."
A life's work

The playbook graveyard sits in a ranch in rural Chester County, Pa. That's where Dick Vermeil goes to get lost in
paper and the past. Here you'll find the masterpieces, thick binders that won playoff games and made defensive
coordinators dizzy.
Somewhere in the stash you'll see a Del Mar High School playbook from the early 1960s, when Vermeil was a
young assistant. If a playbook is an accumulation of a coach's knowledge, Vermeil added pages every year.
His 1982 version with the Eagles totaled about 700 pages. That was when some coaches still weren't using them.
One time in St. Louis, a disgruntled player who got cut swiped his massive playbook and tried to sell it.
"I can't even tell you who it was," Vermeil said.
High-powered men have been at his ranch, CEOs of major corporations, established businessmen. When Vermeil
opens one of his playbooks, he's bound to elicit some puzzled looks.
Then he puts it away. Sacred things are meant to be kept secret.
"You show it to an everyday person and they can't get over it," he said. "They just couldn't envision what was
going into NFL preparation."
Scott Boehm/Getty
Images"You show it to an
everyday person and they
can't get over it," former
coach Dick Vermeil says of
an NFL playbook.
2007 NFL PREVIEW

In our 2007 preview, 'Secrets of The Game," we take you inside the NFL, with stories on the playbook, video
preparation and a peek at Peyton Manning's passing camp.
THE BASICS
Team-by-team previews, more
Power rankings: Pats clear No.1
For your ears only: SB predictions, more
Our experts' picks... | ...and yours
SPORTSNATION
Vote: And the Super Bowl teams will be...
Vote: NFL 101 | Week 1 Pick 'em
Rank 'em: Teams | MVP favorites | QBs
DAY 1: Mystery of the playbook
The NFL's sacred diary of trust
Scouts Inc on go-to plays: AFC | NFC
Inside an '04 playbook | 10 pages from it (PDF)
Playbook stories: Lost, found, confused
Pasquarelli: How different are they?
Elizabeth Merrill is a senior writer for ESPN.com. She can be reached at merrill2323@hotmail.com.

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Exhibit 98

Norv Turner, able to produce only a 7-6 record with
the most expensive roster in NFL history, was fired
today as coach of the Washington Redskins.

Turner was dismissed by owner Dan Snyder one day
after a 9-7 loss to the New York Giants. It was the
Redskins fourth loss in five games and third straight
at home, and it moved a team with Super Bowl
aspirations precariously close to elimination from the
playoff race. Passing game coordinator Terry Robiskie
was named the coach for the rest of the season.

Master Offensive Strategist Turner, hired as a first-
time head coach by late owner Jack Kent Cooke in
1994, was third in seniority among NFL coaches
behind Pittsburghs Bill Cowher and Tennesees Jeff
Fisher. But Turners record was only 49-59-1,
including 8-21-1 in games decided by three points
or fewer. Turner did not have a come-from-behind
victory in the fourth quarter until his fifth year as
coach, and it took six years for him to get the
Redskins to the playoffs. That came last season, when
Washington won the NFC East with a 10-6 record and
defeated Detroit in the first round of the postseason
before losing 14-13 at Tampa Bay. Turner, 48, earned
a reputation as a master offensive strategist with the
Dallas Cowboys, where he was the offensive
coordinator for two Super Bowl teams in the early
1990s. Some of his game plans in Washington were
truly masterful, but his lack of communication skills
and his inability to keep players focused and
motivated led to his downfall. Then season, the stakes
became higher when Snyder spent millions on some
of the biggest names in the sport: Deion Sanders,
Bruce Smith, Jeff George, Mark Carrier, draft picks
LaVar Arrington and Chris Samuels and defensive
coordinator Ray Rhodes. Snyder also signed running
back Stephen Davis to the most lucrative contract in
league history and tested the limits of fan devotion by
charging admission to watch practices at training
camp. The total player payroll of salaries and
bonuses for the season is about $100 million. But
immediately it was apparent that the Redskins
mirrored the recent Baltimore Orioles and New York
Rangers, two other notable teams that essentially
failed to buy a championship. Ego bruising among
the big names wasnt a problem; overconfidence was.

Losses to Detroit A narrow season-opening victory

over Carolina was followed by a losses to Detroit and
injury-riddled Dallas. A five-game winning streak
followed, but the only dominant victories came
against the Giants and Jacksonville Jaguars. A loss to
lowly Arizona followed by a victory on the road at
Super Bowl champion St. Louis exemplified the teams f
ickle nature, then back-to-back home losses to
Philadelphia and the Giants did Turner in. Injuries
also slowed the offense. Three starters were lost for
the season and several other played hurt, and the
reconstituted offensive line had its worst day Sunday.
However, injuries couldnt for unforced errors such
as dropped balls, missed blocks and bad snaps.
Turner began coaching as a graduate assistant at
Oregon in 1975. John Robinson hired him as an
assistant at USC a year later, and Robinson also
brought Turner into the NFL with the Los Angeles
Rams in 1985. Robiskie, 46, a former offensive
coordinator with the Oakland Raiders, was one of
Turners first hires in Washington in 1994. He is
known for a tough-love coaching style from his
dealings with temperamental Redskins receivers
Michael Westbrook and Albert Connell.

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Norv Turner Fired as Redskins Coach
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Exhibit 99


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Daniel Snyder's coaching carousel spins again

I've always been a little uncomfortable with the "Six Coaches in 10
Years" accusation leveled at Dan Snyder. He inherited Norv Turner, and
interim coach Terry Robiskie shouldn't really count on that ledger. "Six in
10" sounds great, but it doesn't seem entirely fair.
But now, with reports that Jim Zorn has been fired, we'll be on to 5 in 10,
and it's a legit 5 in 10, with all of these head coaches hired by Dan
Snyder, and all of them departed under his watch. Let's review.

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Page 1 of 9 D.C. Sports Bog - Daniel Snyder's coaching carousel spins again
6/1/2011 http://voices.washingtonpost.com/dcsportsbog/2010/01/dan_snyder_fires_another_coach.html

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May, 1999: Snyder takes over Redskins ownership, says he will retain
Norv Turner for the time being.
"We've really focused and dedicated and put pressure on when needed,"
Snyder tells The Post. "And we will put the pressure on. I think people
generally perform better under pressure....We will be there and the
players and the management of the Redskins will understand that we
want to win. We didn't do this to have losing seasons."

Dec., 2000: Turner is fired with his team 7-6; Robiskie takes over as
interim coach.
"This was something out of need," Daniel Snyder says. "There are three
games to go. We are in the playoff hunt. We felt it was in the best interest
of the organization."

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Jan., 2001: Marty Schottenheimer is hired.
"Marty Schottenheimer knows how to win, and that's what Redskins fans
demand in a coach," Snyder says in a statement. "I believe we have a
solid player foundation at the Redskins. We're now pairing that with a
coach who understands what it takes to be successful in the NFL."
"This is Marty Schottenheimer's organization from the standpoint of the
final word," Snyder says at the news conference the following day. "I
don't think there's a better man for the job. ... His record speaks for itself.
... This is the first official stamp that Dan Snyder is putting on this football
team. ... As Marty found out, I'm not as hands-on as it may seem
because I'm young and I'm in the building."

Jan., 2002: Schottenheimer is fired.
"I tried to make this work," Snyder says. "It became clear I could not
bring in a quality general manager without giving that individual the right
to make personnel decisions. Marty would have had full participation in
all the player decisions. If there were any disagreements, I would have
served as the tiebreaker."

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Jan., 2002: Steve Spurrier is hired.
"Steve Spurrier will bring a supercharged, exciting and dynamic brand of
football to our great fans," Snydeer says in a statement. "His ability to
energize players and teams is unprecedented. The Redskins deserve to
be back at the Super Bowl and I am immensely confident that Steve is
the coach to get us there."
"I'm fully committed to him, no matter what," Snyder tells The Post's Liz
Clarke a few days later. "I'm going to stand by him through hard times,
good times, et cetera. ... He is the head coach of the Redskins for five
years, at a minimum. I've staked my credibility -- along with his --
together. I hope we have a successful season. I think and pray that we
will. But if we don't, I will stand by Coach Spurrier for however long it
takes because he will get it right. He's a winner."

Dec., 2003: Spurrier resigns.
"I have accepted Steve's resignation with much regret, but respect his
decision," Snyder says in a written statement.


Jan., 2004: Joe Gibbs is hired.
"Joe Gibbs helped define what the Washington Redskins stand for --
integrity, hard work, determination, winning and championships," Snyder
says in a written statement. "Who better to set our strategy and lead the
Redskins back to championship glory."
"I feel like with Joe's leadership skills and great understanding of the
Redskins, there's no other person in the world that I'd rather determine
the direction of the Redskins," Snyder tells The Post later in the week.
"This is going to be wonderful and fun. Joe is going to do this a long time,
and I fully expect him to hang around after he's done coaching."

Jan., 2008: Joe Gibbs retires.
"Joe's done a great job of stabilizing a situation that became unstable
before, quite frankly, and really took hold," Snyder says at the news
conference. "He's taught me a lot. I've learned a tremendous amount
from him and just enjoyed it. It's been a great four years. I wanted
another five-plus."


Feb., 2008: Jim Zorn is hired.
"We're proud that our search was diligent, thorough, and resulted in
today's announcement," Snyder says in a statement. "Jim's track record
and reputation as a player, great teacher, and as a coach makes us
confident that they will translate to success for the Redskins."
"I said we'd be thorough and we'd conduct a full process and we did,"
Snyder says at the news conference. "We did just what we said we'd do.
What we were looking for was a coach with characteristics. And our
characteristics were starting with character, a character person. Joe
[Gibbs] has such character and I've learned so much not only about him,
but about what I and the Redskins want in the future. We also talked
about leadership, great leadership, but it starts with character. It starts
with a person's character, their integrity, their smarts, their drive, their
energy, their passion. We ended up with the right guy. We ended with a
person that has all of those plus much, much more."

Jan., 2010: Zorn is fired. Play-by-play announcer Larry Michael officially
announces the news by reading a press release on ESPN 980.
By Dan Steinberg | January 4, 2010; 6:45 AM ET
Categories: Redskins

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Well one thing this article shows is that Snyder is a terrible judge of character and
talent. He has no credibility at this point.
I continue to hold that as long as Snyder owns the team the Skins will never be a
championship team. If Mike Shanahan is the next in line, and somehow manages
to turn the Skins into a playoff team, his success would be in spite of Dan Snyder,
not because of it.
Posted by: Punisher703 | January 4, 2010 7:23 AM | Report abuse
I wonder if Snyder reads these quotes like Red from Shawshank Redemption every
time he's up for parole.
Posted by: peterandmeredith | January 4, 2010 7:26 AM | Report abuse
Breaking news! Snyder has hired and fired a bunch of coaches!!!
Remember when DC used to be a two paper town and both sides strove for high
quality reports in order to compete with each other?
Posted by: PowerBoater69 | January 4, 2010 7:40 AM | Report abuse
Difficult transition for this franchise. Hail to the maroon and black. And yellow.
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Posted by: iofferkicks383 | January 4, 2010 9:30 AM | Report abuse
Worth 10,000 words, man. Thanks.
Posted by: Pepper5 | January 4, 2010 9:43 AM | Report abuse
Are Larry Michael and ESPN 980 part of the team PR operation? Is there any
semblance of objectivity?
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Comments

Exhibit 100
Patriots vs. Redskins
By Kevin Hassett
From the Magazine: Friday, November 17, 2006
Filed under: Culture, Economic Policy
Who has it right, and who has it wrong? KEVIN HASSETT on the
economics of managing an NFL football team.
Economists optimistically dub their field a social science because they hope that immutable
fundamental laws of the economy like Isaac Newtons laws of physics lurk underneath it all. But
economics depends on human behavior, and Newton was never tempted to study man. I can calculate
the motion of heavenly bodies, he wrote, but not the madness of people. Good decision. People are
different from particles, and there is mounting evidence that, thanks to the vagaries of humans, a lasting,
unified economic law book is beyond our grasp. Consider the National Football League.
Football teams have a relatively simple economic problem to solve. They have to fill their
rosters with players, and have to pay the entire collection of players an amount fixed by the
league. They can add players in two main ways: sign veterans as free agents or hire new
players out of college in a league-wide draft. Veteran free agents get a salary set in the free market. Most
draftees receive a relatively lower salary set by collective bargaining. What they are paid depends on the
round in which they are drafted.Economics has a very clear prediction for optimal team behavior. Firms
should load up on draft picks, especially from the inexpensive late rounds. Every team has the same
cumulative salary to pay, so, to outperform the other teams, you must receive higher value relative to
salary from your players than your opponents receive from theirs. If, for example, you select a Pro Bowl
(all-star) receiver in the fifth round of the draft, that player may well receive a salary one-tenth that of a
veteran Pro Bowl receiver of roughly equal talent who has had his salary set on the market. So your
team gets a huge surplus.
It is nearly impossible to derive surplus from the veteran free-agent market, since you are paying market
wages. While injuries and emergencies might require some veteran signing, the draft is the only place to
build a winning team.
So economics would predict that teams would uniformly put an enormous effort into perfecting their
drafts, and avoid sinking excessive dollars into costly free agents. In fact, this model predicts very well
the behavior of one team, the New England Patriots. Their head coach, Bill Belichick, who received his
undergraduate degree in economics from Wesleyan University in Connecticut, has been an artist at
squeezing value-added out of his draft picks, and has won three of the last five Super Bowls.
This economic brilliance was on display in September, when Belichick traded disgruntled receiver Deion
Branch to the Seattle Seahawks for a first-round draft pick. The Seahawks gave Branch a $39 million
contract, guaranteeing that they would achieve little value-added at that position. So Belichick burdened
3DWULRWV
Page 1 oI 2 Patriots vs. Redskins The American Magazine
6/1/2011 http://www.american.com/archive/2006/november/patriots-vs-redskins/articleprint
the salary cap of a rival with a fat obligation, and took home a valuable draft pick for his own team.
Belichick keeps winning because so many others in the league behave so strangely. Two economists,
Cade Massey of Yale and Richard Thaler of the University of Chicago, studied years of draft history and
found that teams make systematic errors that reflect a serious economic illiteracy. Coaches and general
managers place too high a value on the top few picks, and too low a value on picks a bit further down.
The Washington Redskins are perhaps the leading exemplar of this tendency toward irrationality. Last
spring, for example, the Redskins gave up key draft picks for high-priced veteran players. An especially
silly trade gave the Jets three Redskins picks: in the second and sixth rounds this year and in the
second round next year. The trade left the Redskins with only one pick in the first three rounds this year.
To compound this error, the Redskins filled their roster with mediocre, high-priced veterans,
dropping $35 million on safety Adam Archuleta, $32.5 million on defensive lineman Andre Carter, $31
million on wide receiver Antwaan Randle El, and $25 million on wide receiver Brandon Lloydnone of
whom has ever been in the Pro Bowl.
The problem for economics is that teams like the Redskins continue to exist, and are not driven out by
competitive forces. They confound our ability to model for two reasons. First, it is impossible to conceive
of what foolish thing the Redskins might do next. Second, their behavior can alter the decision framework
for the fully rational teams. If the Redskins are going to bid up the prices of all wide receivers, for
example, then a team like the Patriots has to adjust (as they did) and load up on cheaper pass-catching
tight ends.
The Redskins are not driven out of business because there is a high demand for football in Washington,
and the NFL has a monopoly. A wisely run team cannot enter Washington and compete for Redskins
fans.
Results like Masseys and Thalers have revealed unusual irrational behavior, not just in the NFL but
throughout the economy. Why? Because many firms exist in areas that are walled off from competition
by regulation, by patents, or by their own large scale. Since the entire economy is just the sum of such
pieces, its ebbs and flows will, as Newton long ago concluded, forever be a mystery.
Economics will always be helpful at identifying the answers to narrow questions, like how firms on
average respond to a change in tax policy. But, as for a unified theory of everythingbetter forget it.
5HGVNLQV
Kevin Hasett is director of economic policy studies at the American Enterprise Institute.
Subscribe to The American
Page 2 oI 2 Patriots vs. Redskins The American Magazine
6/1/2011 http://www.american.com/archive/2006/november/patriots-vs-redskins/articleprint

Affidavit Exhibits 51-100 in Motion To Dismiss in Dan Snyder v. Washington City Paper and Dave McKenna

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IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

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