9 Apr 2018
Madison Brengle (Plaintiff)
vs
WTA Tour Inc, ITF Limited a/k/a International Tennis Federation, International Doping Test & Management AB, Stuart Miller, and John Snowball (Defendants)
Complaint
Circuit Court in and for Manatee County, Florida
Filing # 70425427 E-Filed April 9, 2018 01:40:32 PM
Madison Brengle has been a professional tennis player on the WTA Tour since 2007.
In this complaint the Athlete Madison Brengle holds the Defendants responsible for their conduct in subjecting Brengle to anti-doping blood testing using needles despite Defendants knowing and ignoring that she suffers from a rare medically-diagnosed physical condition which results in both temporary and permanent physical injury, emotional trauma, and pain and suffering from having a needle inserted into her vein, and thereafter extracting punishment and repeatedly harassing Brengle following her challenge to this conduct.
Madison Brengle contends that as a result of Defendants' bullying behavior and actions toward Brengle, which caused her to suffer professionally and personally, Brengle no longer has normal strength in her arm and endures post-trauma injuries that cause both physical and emotional damage.
Requested by the ITF Brengle underwent an independent medical assessment with the neurologist Dr. Argoff. In July 2017, Dr. Argoff examined Brengle and confirmed that she suffers from Complex Regional Pain Syndrome (CRPS) Type I. CRPS is manifested by chronic pain, which usually affects a person's arm or leg and the condition is induced by venipuncture.
In Dr. Argoff's written report, he recommended that Brengle not be subject to venipuncture and, to the extent that Brengle must undergo anti-doping testing, that tests be performed without utilization of venipuncture. Other forms of blood testing that can effectively substitute for venipuncture are, and at all relevant times have been, available.
Based upon Dr. Argoff s examination, in August 2017, ITF, the World Anti-Doping Agency (WADA), and the United States Anti-Doping Agency (USADA) provided Brengle with a one-year conditional exemption from venipuncture blood testing after years of Brengle's pleas and requests. Brengle, by that time, had suffered both temporary and permanent physical injuries, emotional trauma and lost earnings.