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U.S. ◄ REPRES HOUSE OF Staff Report Conduct Detrimental: How the NFL and the Washington Commanders Covered Up Decades of Sexual Misconduct ENTATIVES Committee on Oversight and Reform U.S. House of Representatives December 8, 2022 oversight.house.gov

EXECUTIVE SUMMARY I. II. III. IV. BACKGROUND THE COMMITTEE'S INVESTIGATION UNCOVERED NEW EVIDENCE OF THE TOXIC WORK ENVIRONMENT AT THE COMMANDERS, INCLUDING THE ROLE PLAYED BY THE TEAM'S LEADERSHIP.. A. B. 1. B. 14 A Toxic Work Environment Pervaded the Commanders Organization 14 Witnesses Told the Committee that the Team's Owner Personally Engaged in Misconduct and Contributed to Toxic Workplace Conditions... 17 2. Witnesses Stated that Mr. Snyder Was a "Hands-on" Owner Who Endorsed the Toxic Culture at the Commanders Organization....…......…... 19 Mr. Snyder Blamed Others for the Toxic Workplace Culture ............. 21 THE COMMANDERS' OWNER LED INTENSIVE EFFORTS TO OBSTRUCT INVESTIGATIONS INTO MISCONDUCT AT THE TEAM, INCLUDING THE WILKINSON INVESTIGATION AND THE COMMITTEE'S INQUIRY 3. A. Obstruction of the Wilkinson Investigation ..... 1. 2. TABLE OF CONTENTS 3. 4. 2. Witnesses Stated that Mr. Snyder Personally Engaged in Sexual Misconduct Towards Commanders Employees and Contributed to a Toxic Culture 17 3. 4. Mr. Snyder Used a Defamation Lawsuit in India to Target Former Employees and Influence the Wilkinson Investigation........ 4 10 Mr. Snyder Tried to Block Ms. Wilkinson's Access to Sexual Assault Allegations Against Him .. Mr. Snyder Interfered with the Committee's Investigation. 1. The Team's Owner Sought to Dismiss Alleged Misconduct as a Recent Smear Campaign Despite Knowledge That the Team's Workplace Culture Had Been Under Investigation for Years.... 32 .23 23 23 34 Mr. Snyder Waged a Campaign to Blame His Former Team President for the Commanders' Workplace Culture 41 43 2 Mr. Snyder Leaked Derogatory Documents About Witnesses in Apparent Retaliation for Their Cooperation with the Committee. The Commanders Refused to Release Committee Witnesses and Former Employees from Non-Disclosure Agreements. 45 The Commanders Blocked the Committee's Access to Key Documents ... 47 Mr. Snyder Refused to Attend a Public Hearing and Failed to Provide Full and Complete Testimony at his Deposition .49 THE NFL FAILED TO ADDRESS MR. SNYDER'S INTERFERENCE AND HELPED COVER UP THE COMMANDERS' TOXIC WORK ENVIRONMENT 53 .43

V. A. B. C. The NFL Failed to Address Mr. Snyder's Interference in the Wilkinson Investigation 1. 2. 3. 4. 1. 2. The NFL Sought to Portray the Wilkinson Investigation as a Voluntary Inquiry Initiated by the Team, Even Though it was Required by League Policy 3. The NFL Was Aware that Mr. Snyder Tried to Block Ms. Wilkinson's Access to Key Information. The NFL Allowed Mr. Snyder to Target His Accusers and Impede the Wilkinson Investigation...... The NFL Buried Ms. Wilkinson's Findings and Negotiated the Investigation's Outcome with Mr. Snyder, Failing to Hold Him Accountable The NFL Buried the Findings of the Wilkinson Investigation....... The NFL Allowed Mr. Snyder to Negotiate the Outcome of the Investigation...... 57 The NFL Was Aware of Mr. Snyder's Campaign to Blame Mr. Allen for the Commanders' Toxic Workplace.. 60 54 The NFL's Mishandling of the Wilkinson Investigation Reflects a Broader Pattern of Failing to Take Workplace Misconduct Seriously.. 54 CONCLUSION: THE NFL'S HANDLING OF TOXIC WORKPLACE CONDUCT SHOWS THE NEED FOR INCREASED OVERSIGHT AND LEGISLATIVE REFORMS TO PROTECT WORKERS. 56 3 The NFL Failed to Prevent Mr. Snyder's Continued Involvement in the Commanders' Daily Operations 71 61 61 64 74 78

EXECUTIVE SUMMARY This staff report presents findings from the Committee on Oversight and Reform's investigation into the Washington Commanders' (Commanders) decades-long toxic workplace culture, the National Football League's (NFL) response to this troubling conduct, and the NFL's role in setting and enforcing workplace standards across the League. Congress has a responsibility to ensure all Americans are safe from sexual harassment and abuse in the workplace, and the NFL-which has one of the most prominent platforms in America—has a long and troubling history of workplace misconduct. The Committee launched this investigation last October after the League failed to release detailed findings from an internal investigation by an attorney, Beth Wilkinson, who found that "[b]ullying and intimidation,” “sexual harassment,” and a “culture of fear” pervaded the Commanders organization “for many years” and that senior executives not only failed to stop it but “engaged in inappropriate conduct themselves." Despite acknowledging these alarming conclusions, the NFL refused to disclose the full scope of conduct or seek meaningful accountability. Over a period of 12 months, the Committee conducted interviews and depositions, held a roundtable with former employees who experienced sexual harassment and assault while working for the Commanders, and convened a hearing at which NFL Commissioner Roger Goodell testified. The Committee also released interim findings and referred information about potential financial improprieties to federal and state law enforcement agencies, which reportedly led to additional investigations by the NFL, state attorneys general, and the United States Attorney's Office for the Eastern District of Virginia. The Committee's investigation also informed legislation introduced by Chairwoman Maloney—and supported by the NFL Commissioner to prevent future misconduct at workplaces across the country. Despite making public pledges to cooperate with the Committee's investigation, the NFL and the Commanders did not fully comply with the Committee's requests for documents and information. The League, working closely with the Commanders through a previously undisclosed common interest agreement, refused to produce more than 40,000 responsive documents, including the findings of the Wilkinson investigation and materials from Ms. Wilkinson's files. Commanders owner Daniel Snyder-who owned the Team during the two decades when workplace misconduct was rampant in the organization—also obstructed the Committee's inquiry. Mr. Snyder was invited to testify at a public hearing but refused to appear and then sought to avoid service of a subpoena while abroad with his yacht. Mr. Snyder ultimately sat for a private deposition but failed to provide full and complete testimony. Over the course of the deposition, he claimed more than 100 times that he could not recall the answers to the Committee's questions, including basic inquiries about his role as Team owner and multiple allegations of misconduct. Mr. Snyder also gave misleading testimony about his efforts to interfere with the Wilkinson Investigation. 4

Despite this obstruction, the Committee learned substantial new information over the course of this investigation, in part from whistleblowers who came forward to reveal the truth about the Commanders' toxic workplace, the League's response, and the need for legislative action to protect workers in the future. Key findings include: Dozens of employees at the Commanders were harmed by a toxic work culture for more than two decades. The Team's owner permitted and participated in this troubling conduct. O O O The Committee's February 3, 2022, roundtable revealed allegation that Mr. Snyder inappropriately touched former employee Tiffani Johnston at a work dinner and attempted to "aggressively push” her into his limousine until he was stopped by onlookers. Brad Baker, a former video production employee, described how Team executives "tasked us with producing a video for Snyder of sexually suggestive footage of cheerleaders, obviously unbeknownst to any of the women involved." Melanie Coburn, a former cheerleader and marketing employee, stated: "At cheerleader auditions one year, Mr. Snyder ordered the director of the squad to parade the ladies onto the field while he and his friends gawked from his suite through binoculars." Dave Pauken, the Team's former Chief Operating Officer, testified, "There wasn't a year that went by where Dan didn't push me to allow Dennis Greene or other people in the sales and marketing staff to allow sponsors or other paying guests to attend a calendar shoot," indicating that the Team's owner personally encouraged the exploitative practice previously exposed by the New York Times. Bruce Allen, the Commanders former President testified that, "from time to time," Mr. Snyder would warn him: “I want to know everything. Don't let me find out about it." In his Committee deposition, Mr. Snyder purported to "apologize for any workplace misconduct of the team," but he blamed others around him and minimized the experiences of more than 100 current and former Commanders employees who had spoken up about the Team's toxic culture, claiming their stories were “possibly” orchestrated by a former employee with a “negative agenda” whom Mr. Snyder had accused of trying to bribe his staff. 5

Commanders' leadership perpetuated a toxic workplace culture by ignoring and downplaying sexual misconduct by senior male Commanders employees. O Mr. Pauken testified: "There was a [female] member of the public relations staff that was groped by a member of the coaching staff at an event." He described how he "talked to Dan about it, and I knew what we were going to do and which was nothing. And we told the person to just stay away from the coach, we would do our best to keep the coach away from you, but stay away from the coach." Brian Lafemina, the Commanders' former President of Business Operations and Chief Operating Officer, testified that he informed Mr. Snyder that an employee "had come to him to let him know that she had felt uncomfortable over a period of time with her interactions with senior executive Larry Michael, the fact that he had commented about her appearance in public at events where he was the emcee and she was working the event, and that at times he had touched her on the cheeks and kissed her on the forehead." According to Mr. Lafemina, Mr. Snyder responded that “Larry was a sweetheart and that Larry wouldn't hurt anybody." The owner of the Commanders interfered with the Wilkinson Investigation by launching a shadow investigation into suspected sources of the Washington Post exposés, attempting to block Ms. Wilkinson's access to information, and trying to silence employees who could implicate him in misconduct. The Committee found that Mr. Snyder abused the subpoena power of federal courts on at least ten separate occasions by filing a defamation lawsuit against an obscure media company in India in order to obtain private emails and communications from his perceived detractors in the United States, including former employees who spoke out about sexual misconduct at the Commanders. In his Committee deposition, Mr. Snyder testified that his shadow investigation had “[n]othing to do with the workplace investigation" and instead "had to do with the fact that we were defamed" on a website based in India. However, this testimony appears to be misleading at best. The Committee uncovered evidence that Mr. Snyder and his lawyers made at least seven presentations to the NFL and Ms. Wilkinson aimed at convincing the League that Mr. Snyder was the victim of a smear campaign related to misconduct allegations and that others were to blame for his team's toxic workplace. Mr. Snyder and his attorneys made only a single presentation to former Attorney General Loretta Lynch, who Mr. Snyder said had been hired by the NFL to review his defamation 6

O O allegations. That presentation "covered some of the same subject matter presented to the Wilkinson firm.” Mr. Snyder claimed in his deposition that a 100-page dossier created by his lawyers was "solely" related to his defamation lawsuit in India and had "nothing" to do with the Wilkinson investigation into the Commanders' workplace. However, the Committee confirmed that Mr. Snyder's lawyers shared this dossier with Ms. Wilkinson's firm and that the dossier itself is closely related to the facts underlying the Wilkinson Investigation. Dozens of slides discuss the journalists who wrote the Washington Post exposés on the Team's toxic workplace and the victims identified in the articles called the "Accusers" in the dossier. Throughout the Wilkinson Investigation, Mr. Snyder sent private investigators to the homes of former employees. Mr. Allen testified in a Committee deposition that around March 2021, Mr. Snyder sent private investigators to his home in Arizona. The investigators told Mr. Allen that they were "just here to follow you" and "document your actions." Mr. Allen testified that Mr. Snyder commented on his plans to use of private investigators to follow other individuals, including Commissioner Roger Goodell. Mr. Snyder used former Commanders General Counsel Dave Donovan as a proxy to sue Ms. Wilkinson in federal court to block her from accessing or disclosing information related to a 2009 sexual assault allegation, including a $1.6 million confidential settlement. Documents show that Ms. Wilkinson accused the Commanders of intervening "in the Donovan litigation and launch[ing] a series of attacks against Ms. Wilkinson." Mr. Snyder offered hush money to silence several former employees during the Wilkinson Investigation. New evidence shows that in February 2021, lawyers for Mr. Snyder "offered financial compensation" to former employees "who did not have live legal claims, but who had been vocal in their criticisms of the Team in order to secure additional non-disclosure agreements (NDAs) and keep them from talking further.” In addition to failing to appear at a public hearing, Mr. Snyder interfered with the Committee's investigation by intimidating witnesses and blocking the production of documents. Contrary to claims by Mr. Snyder's counsel that Mr. Snyder "never prevented” former cheerleader Abigail Dymond Welch “from sharing information with the Committee," Mr. Snyder refused to release Ms. Welch and other witnesses from their non-disclosure agreements to facilitate their full and complete testimony before the Committee. 7

On the eve of Mr. Allen's deposition, lawyers for Mr. Snyder sent the Committee a batch of internal emails containing inappropriate content from Mr. Allen's Commanders email account so "that Mr. Allen will have an opportunity to review them prior to his deposition." The emails included those that had been leaked to the Wall Street Journal and New York Times in October 2021. Mr. Snyder used a secret common interest agreement with the NFL to prevent the League from turning over more than 40,000 documents from the Wilkinson investigative file to the Committee, including the Wilkinson Investigation findings, several PowerPoint presentations that Mr. Snyder made to the NFL and Ms. Wilkinson during the Wilkinson Investigation, a 2018 human resources audit report showing deficiencies in the Commanders' human resources department, a 2009 confidential settlement that resolved sexual assault allegations against Mr. Snyder, and 2008 and 2010 videos of outtakes from cheerleader photoshoots. The NFL was aware of serious interference with the Wilkinson Investigation but failed to take action to stop it. New evidence uncovered by the Committee shows that the NFL was repeatedly notified that Mr. Snyder continued to use private investigators even after the League instructed him to stop "investigating any of these matters" in August 2020. In April 2021, Bruce Allen notified the NFL that Mr. Snyder had sent private investigators to his home, and in September 2021 an attorney representing Brad Baker informed the NFL that private investigators had contacted her client's friends and family members. A senior NFL official, Senior Vice President and Special Counsel for Investigations Lisa Friel, admitted in a private communication with Mr. Allen more than a year ago that Mr. Snyder's shadow investigation and abuse of federal courts violated NFL policy. Mr. Allen testified that around April 2021, he notified NFL's counsel that Mr. Snyder had used emails from his Commanders email account in a federal court action. In response, Ms. Friel acknowledged that Mr. Snyder's action was "conduct detrimental" to the integrity of the League. The NFL misled the public about its handling of the Wilkinson Investigation and continues to minimize workplace misconduct across the League. New evidence uncovered by the Committee shows that key aspects of the NFL's resolution following the Wilkinson Investigation was negotiated with the Team's owner, including the language in the NFL's July 2021 announcement, the $10 million penalty levied against the Commanders, and the recommendations for the Team to implement. 8

Although the NFL claimed that it refused to release written findings to "better preserve" the anonymity of witnesses and the confidentiality of investigative information, in 2014, the NFL authorized the full release of a 144-page report reflecting the findings of an investigation into allegations of harassment and bullying by Miami Dolphins football players "without any redactions or modifications" due to the "extraordinary public interest" in the matter. The investigators in the 2014 matter displayed "sensitivity to issues of privacy and requests for confidentiality" by anonymizing witness names and withholding certain details from publication. Despite the NFL's September 2020 engagement with the Wilkinson law firm to “complete a written report of its findings," Commissioner Goodell testified at the Committee's June 2022 hearing that he abandoned this plan and decided to receive an oral, rather than written, briefing of the Wilkinson findings in October 2020. Ms. Wilkinson, however, stated in recent litigation related to allegations of sexual misconduct against Mr. Snyder: "The public's interest is to know the truth- -one way or another about the matters at issue in this lawsuit." The Committee's investigation shows that the NFL has not protected workers from sexual harassment and abuse, has failed to ensure victims can speak out without fear of retaliation, and has not sought true accountability for those responsible, even after decades of misconduct. Congress should act swiftly to address these deficiencies and protect workers across the United States. 9

I. BACKGROUND On July 16, 2020, the Washington Post published an exposé, based on interviews with 15 former female Washington Commanders employees, detailing allegations of a decades-long pattern and practice of harassment and bullying within the Commanders' organization. The exposé followed multiple reports of turmoil between Team owner Daniel Snyder, who purchased the Commanders in May 1999, and the franchise's three minority owners, who had purchased their shares in 2003 and were seeking to sell their interests the Team.¹ Following the Post report, the Team announced that it had hired Beth Wilkinson, a former federal prosecutor and prominent attorney at Wilkinson Walsh (now Wilkinson Stekloff), "to conduct a thorough independent review of this entire matter and help the Team set new employee standards for the future."² Pursuant to the Commanders' agreement with Wilkinson Stekloff, Ms. Wilkinson would report directly to the Commanders.³ On August 26, 2020, the Washington Post published a second story revealing new allegations of sexual misconduct directly implicating Mr. Snyder. Former employees alleged that Mr. Snyder had directed Team executives to produce lewd videos containing outtakes from annual Team cheerleader swimsuit calendar photo shoots. The Post also reported allegations that Mr. Snyder had personally propositioned a former cheerleader during a charity fundraiser on behalf of the Team's official ophthalmologist, a friend of Mr. Snyder.4 Within days of the second Washington Post report, on August 31, 2020, the NFL announced that it had assumed oversight of the Wilkinson Investigation. On September 4, 2020, the League retained Ms. Wilkinson to report directly to the NFL and complete a written report of her findings.5 ¹ Redskins' Minority Owners Look to Sell Stakes in Team Amid Ongoing Turmoil, Washington Post (July 5, 2020) (online at www.washingtonpost.com/sports/2020/07/05/redskins-minority-owners-look-sell-stakes-teamamid-ongoing-turmoil/). 2 From Dream Job to Nightmare, Washington Post (July 16, 2020) (online at www.washingtonpost.com/sports/2020/07/16/redskins-sexual-harassment-larry-michael-alex-santos/); How Can the Washington NFL Team's Internal Review Be Independent? Legal Experts Weigh In, Washington Post (July 22, 2020) (online at www.washingtonpost.com/sports/2020/07/22/washington-nfl-internalreview-daniel-snyder-bethwilkinson/). 3 Engagement Letter Between Washington Football Team and Wilkinson Walsh LLP (Aug. 3, 2020) (online at https://oversight house.gov/sites/democrats.oversight house.gov/files/2.%202022-02-04%20 %20WFT%20WW%20Engagement%20Letter_Redacted.pdf). 4 Lewd Cheerleader Videos, Sexist Rules: Ex-Employees Decry Washington's NFL Team Workplace, Washington Post (Aug. 26, 2020) (online at www.washingtonpost.com/sports/2020/08/26/redskins-cheerleadersvideo-daniel-snyder-washington/). 5 NFL Taking Over Investigation of Washington Football Team, NFL.com (Aug. 31, 2020) (online at www.nfl.com/news/nfl-taking-over-investigation-of-washington-football-team); Engagement Letter Between National Football League and Wilkinson Walsh LLP (Sept. 4, 2020) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/WW%20NFL%20Engagement%20Letter%20 Sept%204%202020%20%28Redacted%29%20%2815%29.pdf). 10

Documents obtained by the Committee reveal that on September 8, 2020, the NFL and the Commanders entered into a common interest agreement that aligned the parties' legal interests regarding the Wilkinson Investigation and any potential future litigation, allowing them to pursue a "joint legal strategy." The common interest agreement which the Committee publicly released on February 4, 2022-prevented the NFL and the Commanders from releasing, without the other's consent, any information exchanged between the Team and the League during the investigation.7 More than 150 people, including current and former employees, were interviewed as part of the Wilkinson Investigation, and hundreds of thousands of documents were collected. Evidence uncovered by the Committee shows that in or around October 2020, the NFL directed Ms. Wilkinson to abandon efforts to complete a written report and provide an oral briefing instead. 8 On July 1, 2021, the NFL announced the outcome of the Wilkinson Investigation in a press release that contained vague and conclusory findings, including that “the workplace environment ... particularly for women, was highly unprofessional," that “[b]ullying and intimidation frequently took place,” and that “senior executives engaged in inappropriate conduct themselves." The release also claimed: "None of the managers or executives identified as 6 Common Interest Agreement Between National Football League and Washington Football Team (Sept. 8, 2020) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/1.%202022-02-04%20 %20Common%20Interest%20Agreement_Redacted.pdf) (stating, “Whereas, since July 16, 2020, the Parties have shared and continue to share a common legal interest in the integrity of the Investigation and the defense of reasonably anticipated litigation; as well as a common interest in a joint legal strategy to ensure compliance with all applicable state and federal laws...."). 7 See Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, and Chairman Raja Krishnamoorthi, Subcommittee on Economic and Consumer Policy, to Commissioner Roger Goodell, on behalf of the National Football League, Inc. (Feb. 4, 2022) (online at https://oversight.house.gov/sites/democrats.oversight NFL%20re%20Document%20Request.pdf). house.gov/files/2022-02-04.CBM%20RK%20to%20Goodell 8 National Football League, Press Release: NFL Announces Outcome of Washington Football Team Workplace Review (July 1, 2021) (online at https://nflcommunications.com/Pages/NFL-ANNOUNCESOUTCOME-OF-WASHINGTON-FOOTBALL-TEAM-WORKPLACE-REVIEW.aspx); D.C. AG Suing Dan Snyder, Commanders, NFL, Roger Goodell Doesn't Mean Beth Wilkinson Report Will Become Public, CBS Sports (Nov. 10, 2022) (online at www.cbssports.com/nfl/news/d-c-ag-suing-dan-snyder-commanders-nfl-roger-goodell-doesnt-mean-beth wilkinson-report-will-become-public/). ⁹ Committee on Oversight and Reform, Hearing on Tackling Toxic Workplaces: Examining the NFL's Handling of Workplace Misconduct at the Washington Commanders (June 22, 2022) (online at www.congress.gov/117/meeting/house/114933/documents/HHRG-117-GO00-Transcript-20220622.pdf); see also Letter from Robert Kelner, Covington & Burling LLP, on behalf of the National Football League, to Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, and Chairman Raja Krishnamoorthi, Subcommittee on Economic and Consumer Policy (Nov. 4, 2021) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/3.%202022-02-04%20 %20Kelner%20NFL%20Nov.%204%20Letter_Redacted.pdf) (explaining, "The Commissioner requested that Ms. Wilkinson brief him orally on her investigative findings and recommendations."). 11

having engaged in misconduct is still employed at the club." The release provided few details about what Ms. Wilkinson had uncovered. ¹0 The NFL also announced that, based on the outcome of the investigation, the Commanders would pay a $10 million fine and implement a series of recommendations, and Mr. Snyder would "concentrate on a new stadium plan and other matters" while his wife, Tanya Snyder, would "assume responsibilities for all day-to-day team operations” for “at least the next several months." The NFL commended Mr. Snyder for having "recognized the need for change" and taking "important steps" to transform the culture of the Team.¹¹ Despite public pressure, the NFL refused to release the findings of the Wilkinson Investigation and maintained that Mr. Snyder had been held accountable. ¹2 In October 2021, the Wall Street Journal and the New York Times published a series of internal emails containing misogynistic, racist, and other inappropriate content from the Commanders email account of former Commanders President Bruce Allen. The emails included exchanges between Mr. Allen and other individuals, including then-head coach of the Las Vegas Raiders Jon Gruden. 13 On October 21, 2021, the Committee launched an investigation into allegations of a decades-long toxic workplace culture at the Commanders organization, the NFL's handling of the Wilkinson Investigation into this matter, and the NFL's role in setting and enforcing workplace standards across the League. The Committee explained the purpose of the investigation: The NFL has one of the most prominent platforms in America, and its decisions can have national implications. The NFL's lack of transparency about the problems it recently uncovered raise questions about the seriousness with which it has addressed bigotry, racism, sexism, and homophobia-setting troubling precedent for other workplaces. The Committee is seeking to fully understand this workplace conduct and the league's response, which will help inform legislative efforts to address toxic work environments and workplace investigation processes; strengthen protections for women in the 10 National Football League, Press Release: NFL Announces Outcome of Washington Football Team Workplace Review (July 1, 2021) (online at https://nflcommunications.com/Pages/NFL-ANNOUNCESOUTCOME-OF-WASHINGTON-FOOTBALL-TEAM-WORKPLACE-REVIEW.aspx). See e.g., As Pressure Grows, Roger Goodell Again Says NFL Won't Release Details of WFT Investigation, Washington Post (Oct. 26, 2021) (online at www.washingtonpost.com/sports/2021/10/26/wft-formeremployees-letter-nfl-owners/); Former Washington Football Staff Members Demand Investigation's Findings, New York Times (Oct. 26, 2021) (online at www.nytimes.com/2021/10/26/sports/football/washington-football-teaminvestigation html). 11 Id. 12 13 See Jon Gruden Used Racial Trope to Describe NFLPA Chief DeMaurice Smith in 2011 Email, Wall Street Journal (Oct. 8, 2021) (online at www.wsj.com/articles/jon-gruden-email-demaurice-smith11633721045?mod=e2tw); Raiders Coach Made Racist Comment About N.F.L. Players' Union Chief, New York Times (Oct. 8, 2021) (online at www.nytimes.com/2021/10/08/sports/football/nfl-demaurice-smith-jon-grudenracist-comment.html); NFL General Counsel Surfaces in Email Scandal that Led to Jon Gruden's Resignation, Wall Street Journal (Oct. 14, 2021) (online at www.wsj.com/articles/jeff-pash-gruden-emails-nfl-11634261607). 12

workplace; and address the use of nondisclosure agreements to prevent the disclosure of unlawful employment practices, including sexual harassment. 14 As part of this investigation, the Committee sought records from the NFL, including findings from the Wilkinson Investigation and documents collected during that review. Although the NFL produced some documents in response, many were news articles, press clippings, and public court records. ¹5 The League refused to turn over Ms. Wilkinson's findings and at least 40,000 documents collected during the Wilkinson Investigation. Notwithstanding the Commanders and the NFL's obstruction, the Committee's investigation uncovered overwhelming evidence of decades of misconduct at the Team, and concerning evidence showing the NFL's mishandling of that matter. The Committee held a February 3, 2022, roundtable with former Commanders employees regarding the hostile work environment they experienced, and the following day released evidence. The Committee also conducted depositions and transcribed interviews with former Commanders employees and executives. On April 12, 2022, the Committee referred potential evidence of financial improprieties obtained during the investigation to the Federal Trade Commission and the District of Columbia, Maryland, and Virginia state attorneys general. ¹6 16 On June 22, 2022, the Committee held a hearing with NFL Commissioner Roger Goodell, which Mr. Snyder refused to attend, apparently so that he could attend an advertising festival in France.¹7 The Committee also released a memorandum with evidence of Mr. Snyder's efforts to interfere with the Wilkinson Investigation, including by launching a shadow investigation into journalists and former employees who spoke out against the Commanders' toxic workplace.¹ 18 14 Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, and Chairman Raja Krishnamoorthi, Subcommittee on Economic and Consumer Policy, to Commissioner Roger Goodell, on behalf of the National Football League, Inc. (Oct. 21, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Final%202021-10 21.CBM%20RK%20to%20Goodell-NFL%20re%20WFT%20Investigation.pdf). 15 In addition, the NFL produced to the Committee or made available for in camera review certain documents collected from the email account of former Team president Bruce Allen. 16 Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, and Chairman Raja Krishnamoorthi, Subcommittee on Economic and Consumer Policy, to Commissioner Lina M. Khan, on behalf of the Federal Trade Commission (Apr. 12, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-04-12.CBM%20RK%20to%20KhanFTC%20re%20Washington%20Commanders.pdf). 17 Call with Karen Seymour et al., Sullivan & Cromwell LLP, and Majority Staff, Committee on Oversight and Reform (June 27, 2022) (confirming that Mr. Snyder could not attend the hearing due to his plans to attend the Cannes Liones Festival of Creativity in France); Dan Snyder's Plane, Yacht Arrive in Cannes as Attorney Pushes Back Against Congressional Committee, The Roanoke Times (June 20, 2022) (online at https://roanoke.com/sports/professional/dan-snyders-plane-yacht-arrive-in-cannes-as-attorney-pushes-back-against congressional-committee/article_49706d13-910d-524d-9f15-11f65c94b6b9 html). 18 Supplemental Memorandum from Chairwoman Carolyn B. Maloney to Members, Committee on Oversight and Reform (June 22, 2022) (online at 13

19 Chairwoman Maloney introduced two bills to address workplace issues uncovered during the investigation, including legislation to rein in the abuse of non-disclosure agreements to hide workplace misconduct, and a bill to prevent the use of worker's images without their consent. The Committee's findings and referrals have reportedly resulted in additional investigations by the NFL, several state attorneys general, and the United States Attorney's Office for the Eastern District of Virginia. 20 II. THE COMMITTEE'S INVESTIGATION UNCOVERED NEW EVIDENCE OF THE TOXIC WORK ENVIRONMENT AT THE COMMANDERS, INCLUDING THE ROLE PLAYED BY THE TEAM'S LEADERSHIP The Committee's investigation uncovered new evidence including testimony from eyewitnesses and victims of rampant misconduct and a toxic work culture at the Commanders that began as early as 2001 and continued for roughly two decades. Evidence indicates this culture was perpetuated by senior leadership at the Commanders, including the Team's owner. A. A Toxic Work Environment Pervaded the Commanders Organization Former senior Commanders' executives and employees who spoke to the Committee described the Commanders organization as having a culture marred by a cycle of inappropriate conduct and retaliation. Jason Friedman, a 24-year veteran of the Commanders who most recently served as Vice President of Premium Sales, described the Team's culture during most of his tenure as rife with "sexual harassment in the workplace" and "a frat house mentality.” "21 David Pauken, who served as the organization's Chief Operating Officer from 2001 to 2006, testified that neither he nor other former Commanders employees with whom he spoke were "surprised" by the toxic workplace allegations when they were first made public in the 2020 Washington Post articles, describing the environment during his tenure as “overly aggressive, abusive, and demeaning." Executives relayed stories about misconduct by various Team officials and Mr. Snyder himself, https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-06 22%20Supplemental%20Memo%20Tackling%20Toxic%20Workplaces.pdf). 19 H.R. 8146, the Accountability for Workplace Misconduct Act; H.R. 8145, the Professional Images Protection Act. 20 See e.g., Commanders Fined $250K, Must Refund Ticket Deposits in Settlement with MD. AG, Washington Post (Nov. 18, 2022) (online at www.washingtonpost.com/sports/2022/11/18/maryland-ag-settles-withcommanders-over-ticket-deposit-refunds/) (describing investigations by the NFL, U.S. Attorney's Office for the Eastern District of Virginia, and the D.C., Maryland, and Virginia attorney's general offices, resulting from the Committee's investigation). "22 21 Committee on Oversight and Reform, Transcribed Interview of Jason Friedman (Mar. 14, 2022) (online at https://oversight house.gov/sites/democrats.oversight.house.gov/files/2022-03 14%20Transcribed%20Interview%20of%20Jason%20Friedman.pdf). 22 Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0607%20Deposition%20of%20David%20Pauken.pdf). 14

including the exploitation of cheerleaders, unwanted touching or sexual advances, disparate treatment of female employees, demeaning comments, and the hiring of prostitutes during workrelated events. 23 At the Committee's roundtable on February 3, 2022, former Commanders employees described the pattern of misconduct to which they were subjected: Rachel Engleson, a former Director of Marketing and Client Relations, shared that she could not a recall a time when she "didn't experience or fear sexual harassment." She continued, "It was just a pervasive part of the culture, and an unavoidable rite of passage, being a woman who worked there."24 She added that “harassment happened every single day that you were on site. It didn't matter where you were.' 9925 Melanie Coburn, a former director of marketing for the Team's cheerleading program, similarly offered her impression that "the overwhelming majority of 926 She female employees working for the team" were “exploited and harassed." estimated that she was subjected to more than 200 instances of sexual harassment while working for the Commanders, ranging from "sexual objectification comments" to other "uncomfortable situations." She told the Committee she felt like "arm candy at events with all the male executives. Like, it was a very constant thing." "27 23 See e.g., id; Committee on Oversight and Reform, Transcribed Interview of Jason Friedman (Mar. 14, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0314%20Transcribed%20Interview%20of%20Jason%20Friedman.pdf); Committee on Oversight and Reform, Deposition of Brian Lafemina (Apr. 8, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-03-30%202022-0408%20Depositions%20of%20Brian%20Lafemina.pdf). 24 Committee on Oversight and Reform, Statement of Rachel Engelson, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Engleson%20Rachel%20%20Opening%20Statement.220302.Final_.pdf). 25 Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 26 Committee on Oversight and Reform, Statement of Melanie Coburn, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Coburn%2C%20Melanie%20%20Opening%20Statement.220203.Final%282%29.pdf). 27 Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 15

Tiffani Johnston, a former Marketing and Events Coordinator and cheerleader, recalled being sexually harassed 50 to 100 times, including by Mr. Snyder himself, while employed by the Commanders. 28 Ana Nunez, former Coordinator of Business Development and Client Service, similarly recalled being "sexually harassed by multiple male employees, including top executives,” many of whom “had a reputation for mistreating young female employees.' She described being harassed "[o]ver 100 times" and characterized the harassment as "almost a part of my everyday experience."3⁰ "929 Emily Applegate, a former Marketing Coordinator and Premium Client Services Coordinator, estimated that her boss, the Commanders' former Chief Marketing Officer, harassed her over 500 times, noting that it “happened on a daily basis.”³1 These individuals told the Committee that attempts to report misconduct to Commanders leadership were ignored. Ms. Nunez explained that when she reported her near daily harassment at the hands of male executives to superiors “no one did anything about it.” 932 Ms. Engleson stated that when she attempted to report specific instances of harassment that involved unwanted kissing and other advances, her reports were largely ignored. She described one instance in which a new male Team executive “specifically hired to help change the business” was quickly terminated after she reported sexual harassment.³3 Mr. Friedman confirmed that, from his 28 Id. 29 Committee on Oversight and Reform, Statement of Ana Nunez, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Nunez%2C%20Ana%20%20Opening%20Statement.220302.Final_.pdf). 30 Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 31 Id. 32 Committee on Oversight and Reform, Statement of Ana Nunez, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Nunez%2C%20Ana%20%20Opening%20Statement.220302.Final_.pdf). According to an August 2021 report by Vestry Laight, the workplace consulting firm retained by the Commanders to assess changes to the Team's workplace following the Wilkinson Investigation, an assessment conducted by a separate outside consulting firm found that “team members do not know who to go to when a concern arises; some fear retaliation or losing responsibilities if they share concerns." NFL-0000014 (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Exhibit%20J_Redacted.pdf). 33 Committee on Oversight and Reform, Statement of Rachel Engelson, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Engleson%20Rachel%20%20Opening%20Statement.220302.Final_.pdf). 16

perspective as a senior executive, Team leadership preferred to silence employees through termination or nondisclosure agreements rather than address allegations of harassment. ³4 B. Witnesses Told the Committee that the Team's Owner Personally Engaged in Misconduct and Contributed to Toxic Workplace Conditions Although Mr. Snyder denied knowledge of or participation in the allegations of misconduct levied against him by former Commanders employees during his deposition, the examples of misconduct and sexual harassment shared with the Committee were not isolated incidents. 35 Instead, they appear to have been part of a pervasive toxic work environment that senior leaders at the organization, including Mr. Snyder, perpetuated. Several former employees from the Commanders' front office and the marketing and cheerleading teams described Mr. Snyder's contributions to the toxic workplace at the Commanders organization and alleged that he personally engaged in acts of sexual misconduct. 1. Witnesses Stated that Mr. Snyder Personally Engaged in Sexual Misconduct Towards Commanders Employees and Contributed to a Toxic Culture During the Committee's February 3, 2022, roundtable, Ms. Johnston alleged that she had been sexually assaulted by Mr. Snyder. Ms. Johnston disclosed that Mr. Snyder had engaged in unwanted touching during a work-related dinner, stating that he “placed his hand on my thigh under the table" and, later in the evening, "aggressively pushed me towards his limo with his hand on my lower back, encouraging me to ride with him to my car.” 36 Ms. Johnston further shared that Mr. Snyder only stopped his aggressive behavior because his attorney intervened.³7 When she told a senior co-worker about the incident the next day, Mr. Johnston was told "not [to] repeat this story to anyone outside this office door."38 Following the roundtable, the NFL 34 Committee on Oversight and Reform, Transcribed Interview of Jason Friedman (Mar. 14, 2022) (online at https://oversight house.gov/sites/democrats.oversight.house.gov/files/2022-03 14%20Transcribed%20Interview%20of%20Jason%20Friedman.pdf). 35 Committee on Oversight and Reform, Deposition of Daniel M. Snyder (July 28, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-07 28%20Deposition%20of%20Daniel%20M.%20Snyder_Redacted.2.pdf). 36 Committee on Oversight and Reform, Statement of Tiffani Johnston, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Johnston%20Tiffani%20%20Opening%20Statement.220203.UPDATED.pdf); see also Letter from Jason Friedman to Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Letter%20from%20Jason%20Friedman_Redacted.pdf) (corroborating Ms. Johnston's account of Mr. Snyder's attempt to push Ms. Johnston into his limo). 38 Id. 37 Committee on Oversight and Reform, Statement of Tiffani Johnston, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Johnston%20Tiffani%20%20Opening%20Statement.220203.UPDATED.pdf). 17

launched its own investigation into this allegation, led by former U.S. Attorney Mary Jo White. That investigation is reportedly ongoing.³ 39 Several other former employees and executives offered additional information describing actions by Mr. Snyder that inappropriately sexualized the Commanders' cheerleading program: Ms. Coburn informed the Committee that Mr. Snyder ordered a former director of cheerleading to parade cheerleaders onto FedEx Field and to instruct them to "turn around slowly" while Mr. Snyder and his friends "gawked from his suite through binoculars.” "40 According to Mr. Pauken, Mr. Snyder-together with Dennis Greene, another Commanders executive—personally advocated for years that the Team should sell access to cheerleader photo shoots to male sponsors and suite holders an exploitative practice that was exposed by the New York Times in 2018.41 Brad Baker, who worked in the Team's video production department, shared that Larry Michael, the Commanders' longtime broadcaster, ordered the Team's video department to produce a lewd video comprised of outtakes from a cheerleaders' photo shoot showing their exposed intimate body parts without their knowledge or consent, for Mr. Snyder's personal consumption.4 42 39 Mary Jo White Has Not Yet Interviewed Daniel Snyder, NBC Sports (Oct. 27, 2022) (online at https://profootballtalk.nbcsports.com/2022/10/27/mary-jo-white-has-not-yet-interviewed-daniel-snyder/). 4⁰ Committee on Oversight and Reform, Statement of Melanie Coburn, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Coburn%2C%20Melanie%20%20Opening%20Statement.220203.Final%282%29.pdf). 41 Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0607%20Deposition%20of%20David%20Pauken.pdf) (When asked about the allegations detailed in the New York Times during his deposition, Mr. Pauken responded: “That is entirely consistent with the Dennis Green and Dan Snyder that I know."); see also Washington Redskins Cheerleaders Describe Topless Photo Shoot and Uneasy Night Out, New York Times (May 2, 2018) (online at www.nytimes.com/2018/05/02/sports/redskins-cheerleadersnfl.html). 42 Committee on Oversight and Reform, Statement of Brad Baker, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Baker%2C%20Brad%20%20Opening%20Statement.220203.Final_.pdf); Washington Redskins Cheerleaders Describe Topless Photo Shoot and Uneasy Night Out, New York Times (May 2, 2018) (online at www nytimes.com/2018/05/02/sports/redskinscheerleaders-nfl.html); Redskins Front-Office Executive Dennis Greene Resigns, Washington Post (May 31, 2018) (online at www.washingtonpost.com/sports/redskins/redskins-front-office-exec-dennis-greene resigns/2018/05/31/7f2e7ce2-6521-11e8-a768-ed043e33f1dc_story html); see also Redskins Have Non-Cheering Cheerleaders Who Cite Harassment, NBC (online at www nbcwashington.com/news/local/redskins-have-noncheering-cheerleaders-who-cite-harassment-report/150224/) (describing a video on the Commanders' website advertising suites for sale at FedEx Field, showing men in suites "posing with cheerleader ambassadors" and containing an audio voiceover stating: “Membership has its privileges. You and your business are the beneficiaries."). 18

When asked who was responsible for the oversexualization of the cheerleading program at the Commanders, Mr. Pauken answered unequivocally that it was "Dan Snyder." As Ms. Johnston told the Committee, sexualization was part of "the culture he created. It was an abusive one. "44 9943 2. Witnesses Stated that Mr. Snyder Was a "Hands-on" Owner Who Endorsed the Toxic Culture at the Commanders Organization Former Commanders employees told the Committee that Mr. Snyder endorsed a toxic culture at the Commanders in which sexual misconduct, exploitation of women, bullying of men, and other inappropriate behavior was commonplace, and that he was a hands-on owner who had a role in nearly every organizational decision.45 As one witness confirmed, Mr. Snyder “created a culture where this behavior was accepted and encouraged."46 Witnesses testified that on multiple occasions, Mr. Snyder ignored or personally instructed Commanders executives to ignore workplace misconduct by male employees while punishing female employees for conduct arising out of the same set of facts. Mr. Pauken testified that after he informed Mr. Snyder that a senior member of the Team's coaching staff had been accused of sexually assaulting a female member of the public relations staff, Mr. Snyder decided, in consultation with Mr. Pauken, that they “weren't going to confront the coach, and keep [the victim] away from the coach."47 No action was taken against the coach, who remained with the Team for another year. Brian Lafemina, former President of Business Operations and Chief Operating Officer for the Commanders, testified that he informed Mr. Snyder that a subordinate “had felt uncomfortable over a period of time with her interactions 43 Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at house.gov/files/2022-06 https://oversight.house.gov/sites/democrats.oversight 07%20Deposition%20of%20David%20Pauken.pdf). 44 Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 45 See generally Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online athttps://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-06 07%20Deposition%20of%20David%20Pauken.pdf); Committee on Oversight and Reform, Transcribed Interview of Jason Friedman (Mar. 14, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-03 14%20Transcribed%20Interview%20of%20Jason%20Friedman.pdf); Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 46 Committee on Oversight and Reform, Statement of Emily Applegate, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/Applegate%2C%20Emily%20%20Opening%20Statement.220203.Final_.pdf). 47 Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0607%20Deposition%20of%20David%20Pauken.pdf). 19

with Larry Michael," after he "commented about her appearance in public at events where he was the emcee and she was working the event" and had "touched her on the cheeks and kissed her on the forehead." Mr. Lafemina testified that Mr. Snyder responded by describing Mr. Michaels as "a sweetheart" who "wouldn't hurt anybody." Mr. Michael remained the Commanders' announcer until he allowed to retire in lieu of termination in 2020.4⁹ 49 "48 "I want to know everything. Don't let me find out about it.” -Dan Snyder to Bruce Allen, former Team President, according to Mr. Allen's deposition Several former Commanders executives testified that Mr. Snyder was a hands-on owner who participated in every aspect of the Commanders' operations. Mr. Pauken, who was Mr. Snyder's most senior operations executive from 2001 through 2006, testified that Mr. Snyder was involved in every facet of the organization, stating that he was "both hands on. "50 Mr. Pauken explained that Mr. Snyder was "actively involved" in everything from suite sales to sponsorship sales to personnel decisions. For example, although Mr. Pauken was responsible for carrying out employee terminations, he stated that he “would never fire anybody without Dan Snyder knowing and having a chance to weigh in.”5¹ His testimony was consistent with the testimony of Bruce Allen, the Team's President from 2009 through 2019, who described Mr. Snyder as "very involved in the entire operation, in the organization," including both football and business operations.52 Mr. Allen testified that "from time to time," Mr. Snyder would warn him: "I want to know everything. Don't let me find out about it.” "953 In 2018, Mr. Snyder fired the top executive he had hired to lead the Commanders’ operations after seven months on the job. Mr. Lafemina testified that he was "relieved of [his] duties" due in part to "serious disagreements between myself and Dan Snyder about a lot of the 48 ³ Committee on Oversight and Reform, Deposition of Brian Lafemina (Apr. 8, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-03-30%202022-0408%20Depositions%20of%20Brian%20Lafemina.pdf). 49 Larry Michael, Longtime Radio Voice of Washington's NFL Team, Retires, Washington Post (July 15, 2020) (online at www.washingtonpost.com/sports/2020/07/15/larry-michael-retires-washington-nfl-team/). 5⁰ Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0607%20Deposition%20of%20David%20Pauken.pdf). 51 Id. 52 Id. 53 Committee on Oversight and Reform, Deposition of Bruce Allen (Sept. 6, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0906%20Deposition%20of%20Bruce%20Allen_Redacted.pdf). 20

strategies and tactics related to the business operations around marketing, around ticketing, around sponsor strategies, around public relations." 9954 Mr. Snyder's "hands-on” management style was also witnessed by other employees. As Ms. Johnston, who worked for the Team's marketing department, explained to the Committee: "I witnessed it. I witnessed it in marketing meetings. Any marketing flier that went out had to be approved by Dan Snyder. We would be on the phone with him telling us changes, the smallest changes 9955 Mr. Pauken's view of Mr. Snyder's influence on the Commanders' work environment and the Committee's inquiry reflected that of many other individuals interviewed by the Committee: I think that in the end, it all stems from the owner, Dan Snyder. That's what I think. I think that the workplace culture and how he ran the business when I was there, and how I believe he ran it after I left caused the events, set the stage and caused the events to occur where the allegations that came out, whether they occurred or not, I don't know, but those are the kinds of things that led to this investigation. 56 3. Mr. Snyder Blamed Others for the Toxic Workplace Culture During his deposition, Mr. Snyder said, “I've said numerous times, and continue to state, we apologize for any workplace misconduct of the team." Yet evidence uncovered by the Committee shows that Mr. Snyder attempted to blame others around him and minimized the experiences of more than 100 current and former Commanders employees who had spoken to the Washington Post about the Team's toxic culture. In fact, during Mr. Snyder's deposition, he cast doubt on the veracity of the allegations detailed in the Washington Post's July 16, 2020, exposé, claiming they were "possibly" orchestrated by a former employee with a “negative agenda" who he had accused of offering money to Commanders employees "to make up false and outlandish stories about him.”57 54 Committee on Oversight and Reform, Deposition of Brian Lafemina (Mar. 30, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-03-30%202022-0408%20Depositions%20of%20Brian%20Lafemina.pdf). 55 Committee on Oversight and Reform, Roundtable on Examining the Washington Football Team's Toxic Workplace Culture (Feb. 3, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0203%20Transcript%20of%20Roundtable.pdf). 56 Committee on Oversight and Reform, Deposition of David Pauken (June 7, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-0607%20Deposition%20of%20David%20Pauken.pdf). 57 Committee on Oversight and Reform, Deposition of Daniel M. Snyder (July 28, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-07 28%20Deposition%20of%20Daniel%20M.%20Snyder_Redacted.2.pdf); Letter from Tom Davis et al., Holland & Knight LLP, on behalf of the Washington Commanders, to Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform (Oct. 5, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-10 21

Mr. Snyder also blamed Mr. Allen for the Commanders' decades-long toxic environment. 58 In his deposition, Mr. Snyder claimed to believe that Mr. Allen was responsible for the Commanders' toxic workplace culture due to a remark by Mr. Allen about the Team's football program. According to Mr. Snyder, Mr. Allen stated that the Commanders' culture was "actually damned good" during a press conference to announce the firing of former Commanders head coach Jay Gruden. 59 But when pressed at his deposition to provide examples demonstrating specifically how, beyond this comment alone, Mr. Allen was responsible for more than two decades of misconduct at the Commanders at the time of his termination, Mr. Snyder was unable to explain himself: Q: A: Q: A: Q: So what culture are you referring to when you say that there was a workplace culture and you're suggesting that Mr. Allen was responsible for it in 2019? I believe it's four or five days prior to termination of Jay Gruden, who was on TMZ smoking marijuana. And we knew we had a problem, obviously. He was the head coach. Mr. Allen was the head coach? No. I'm referring to four or five days prior to the termination of Jay Gruden at a press conference where Bruce Allen said, we have a damned good culture, it was on TMZ, Coach Jay Gruden was smoking marijuana on a sidewalk somewhere. Crazy video. And we knew that it was an obvious signal there was a culture problem. The culture problem that you're referring to is Mr. Gruden smoking marijuana on TV? 05%20Letter%20from%20Tom%20Davis%20to%20CBM_Redacted.pdf); see also Lewd Cheerleader Videos, Sexist Rules: Ex-Employees Decry Washington's NFL Team Workplace, Washington Post (Aug. 26, 2020) (online at www.washingtonpost.com/sports/2020/08/26/redskins-cheerleaders-video-daniel-snyder-washington/). 58 Letter from Tom Davis et al., Holland & Knight LLP, on behalf of the Washington Commanders, to Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform (Oct. 5, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-10 05%20Letter%20from%20Tom%20Davis%20to%20CBM_Redacted.pdf). 59 Committee on Oversight and Reform, Deposition of Daniel M. Snyder (July 28, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-07 28%20Deposition%20of%20Daniel%20M.%20Snyder_Redacted.2.pdf); Committee on Oversight and Reform, Deposition of Bruce Allen (Sept. 6, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-09 06%20Deposition%20of%20Bruce%20Allen_Redacted.pdf) (stating that Mr. Snyder instructed him to extend Jay Gruden's coaching contract and that his remark about the "damned good" culture was intended as a defense to media criticism of the Team's football program's performance; he explained: "when you say to a locker room that your culture is bad, that means people aren't working hard, that the players aren't trying to win, they aren't doing everything, they're not studying. It's saying that the coaches don't care about the results ... I'm not going to answer a question to say, 'You're right, the culture sucks here with the Redskins,' and have every player just check out for the entire season."). 22

A: III. Q: A: No. I'm referring to, as I said, when Bruce Allen said-answered the question, a damned good culture, we just didn't believe him. A. Other than the marijuana incident, what else can you point to that led you to believe there was a culture that Mr. Allen was responsible for, apart from him defending the Washington Commanders? THE COMMANDERS' OWNER LED INTENSIVE EFFORTS TO OBSTRUCT INVESTIGATIONS INTO MISCONDUCT AT THE TEAM, INCLUDING THE WILKINSON INVESTIGATION AND THE COMMITTEE'S INQUIRY Obstruction of the Wilkinson Investigation During the Wilkinson Investigation, the Commanders' owner filed a foreign lawsuit as a pretext to launch a shadow investigation into individuals he suspected were sources of allegations about the Team's toxic work environment. Using information collected from this shadow investigation, lawyers for Mr. Snyder tried to cast him as the victim of a defamation campaign spearheaded by his former business partners and to deflect responsibility for the Team's toxic work culture. Mr. Snyder also used a variety of tactics to try to block Ms. Wilkinson's access to key information—including using a non-disclosure agreement and offering hush money to silence a victim, sending private investigators to the homes of potential witnesses, and taking advantage of a separate lawsuit filed against Ms. Wilkinson by the Team's former general counsel. We just thought we had some work to do on the culture, and what we needed as a head coach was a mature culture-setting coach. We started there. As I mentioned, we hired Coach Rivera the beginning of 2020. And as I also said earlier, we got to the business side - and would have gotten there earlier too had it not been for COVID. 60 1. Mr. Snyder Used a Defamation Lawsuit in India to Target Former Employees and Influence the Wilkinson Investigation On August 7, 2020, approximately two weeks after the Washington Post published its first exposé, Mr. Snyder filed a lawsuit against an online website based in India, Media Entertainment Arts WorldWide (MEAWW), alleging that it had published defamatory articles. 61 60 Committee on Oversight and Reform, Deposition of Daniel M. Snyder (July 28, 2022) (online at https://oversight.house.gov/sites/democrats.oversight house.gov/files/2022-07 28%20Deposition%20of%20Daniel%20M.%20Snyder_Redacted.2.pdf). 61 Ex Parte Petition for Assistance in Aid of a Foreign Proceeding Pursuant to 28 U.S.C. § 1782, Doc. 1-5, Daniel Snyder Through His SPA Holder vs. Eleven Internet Services, (Jan. 15, 2021) Application/Petition for Assistance in Aid of a Foreign Proceeding Pursuant to 28 U.S.C. 1782, D. N.J. (No. 2:21-cv-00819-BRM-ESK); Washington Owner Daniel Snyder Sues Media Company Over Baseless Stories, Washington Post (Aug. 7, 2020) (online at www.washingtonpost.com/sports/2020/08/07/washington-owner-daniel-snyder-sues-media-companyover-baseless-stories/). 23

In his deposition, Mr. Snyder claimed that he filed suit after he gathered evidence that a former employee (Former Staff 1) attempted to bribe his personal staff by off...