Case 5:11-cv-00123-cr Document 27-2

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EXHIBIT A

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF VERMONT

JAMES JAK KNELMAN,

Plaintiff,
v.
MIDDLEBURY COLLEGE and
BILL BEANEY,
Defendants.

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Docket No. 5:11-cv-123

AFFIDAVIT OF JOHN DAWSON

John Dawson, being duly sworn, deposes and says:

1.

I reside in Watertown, Connecticut where I am employed at The Taft School in

Admissions and as a teacher of History. I also coach girls thirds field hockey and boys varsity
ice hockey.
2.

Briefly, my education and work background is as follows. Upon graduating from

Choate Rosemary Hall, I attended Middlebury College where I majored in history. While at
Middlebury College, I played four years on the mens varsity ice hockey team, serving as
Captain during my senior year. After graduating from Middlebury College in 2004, I worked as
an associate at Morgan Stanley in New York City, where I performed market analysis and equity
and fixed income trading. I then returned to Middlebury College in 2006 to become the
Dinse,

Assistant Varsity Ice Hockey Coach and the Head Junior Varsity Coach, holding those positions

Knapp & McAndrew, P.C.

209 Battery Street

for five years until I joined The Taft School in 2011. During my time as a Middlebury College

P.O. Box 988

Burlington, VT
05402-0988
(802) 864-5751

{B0793340.1 00307-0420}

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assistant hockey coach, I also became involved with USA Hockey, working at their National
Select Festivals during summers.
3.

Accordingly, I was the Assistant Coach of the Middlebury College Mens Ice

Hockey Team from the time that James Jak Knelman came to Middlebury College through and after - the date he left the team. I am personally familiar with and have knowledge of the
circumstances and grounds for Mr. Knelmans suspension and dismissal from the team by Head
Coach Bill Beaney in January 2011.
4.

In this regard, it is important to understand that the weekend of January 14 - 16,

2011, was extremely important for Middlebury College in general and the hockey team
specifically. It was Alumni Hockey Weekend and dedicated to celebrate the 50th anniversary of
one of Middleburys greatest teams - the 1960 - 61 Mens Hockey Team. Attached as Exhibit A1 is a description of that team, its place in Middlebury College sports history, and the 20
members from that team who returned to Middlebury College to celebrate the Weekend and
attend the celebratory alumni banquet on the evening of January 15th. Every player, including
Mr. Knelman, was made aware of the importance of, and need to attend, that banquet. Simply
put, there is no question but that the players understood that failure to attend or early departure
from the banquet (without permission from the Coach) would be a violation of team
expectations.
5.

I learned after the fact that Mr. Knelman left the banquet early and without

receiving permission from, or even providing notice to, the coaches or team captains.
6.

When I spoke with Coach Beaney on Monday, January 17, 2011, he was deeply

Dinse,
Knapp & McAndrew, P.C.

disappointed to have learned of Mr. Knelmans early and unauthorized departure from the

209 Battery Street

P.O. Box 988
Burlington, VT

banquet. This was not the first time that Coach Beaney felt that Mr. Knelman had exhibited

05402-0988
(802) 864-5751

{B0793340.1 00307-0420}
2

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selfish conduct wherein his focus seemed to be on his personal desires rather than the overall
good of the team. I know that on several occasions Coach Beaney had had conversations with
Mr. Knelman as to which position he would play in order to bring maximum benefit to the team,
only to have Mr. Knelman respond by asking if he could instead play more of an offensive role.
After considerable thought over the next week, Coach Beaney ultimately decided that Mr.
Knelman was to be dismissed from the hockey team for the remainder of the season. I know that
Coach Beaney did not make this decision lightly and that he concluded it was the appropriate
response given Mr. Knelmans conduct and attitude. I do know that Coach Beaney also told Mr.
Knelman that he could seek to rejoin the team in the fall of 2011. In my judgment, Coach
Beaney dealt with the situation reasonably and appropriately.
7.

During my five years working with Coach Beaney I regularly observed that he set

high standards for his players, which extended to their conduct both on and off the ice, and as
students and citizens in general. Additionally, I can say unequivocally that Coach Beaney places
the highest importance on academics and insists that his players focus on their studies at
Middlebury College. In fact, I have known Coach Beaney to require players to take temporary
leaves of absence from the team so that they can - and do - dedicate additional time and effort to
their studies and academic responsibilities.
8.

All of my above statements are based on my personal knowledge, experiences,

and observations.

Dinse,
Knapp & McAndrew, P.C.
209 Battery Street
P.O. Box 988
Burlington, VT
05402-0988
(802) 864-5751

{B0793340.1 00307-0420}
3

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EXHIBIT A-1

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