Parrish et al v. National Football League Players Incorporated

Filing 111

Declaration of Ryan S. Hilbert in Support of 110 Memorandum in Opposition, filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4)(Related document(s) 110 ) (Hilbert, Ryan) (Filed on 8/9/2007)

Parrish et al v. National Football League Players Incorporated

Doc. 111

Case 3:07-cv-00943-WHA

Document 111

Filed 08/09/2007

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

MANATT, PHELPS & PHILLIPS, LLP RONALD S. KATZ (California Bar No. 085713) E-mail: [e-mail] RYAN S. HILBERT (California Bar No. 210549) E-mail: [e-mail] NOEL S. COHEN (California Bar No. 219645) E-mail: [e-mail] 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: [phone] Facsimile: [phone] MCKOOL SMITH, P.C. LEWIS T. LECLAIR (Bar No. CA 077136) E-mail: [e-mail] JILL C. ADLER (Bar No. CA 150783) E-mail: [e-mail] 300 Crescent Court Dallas, TX 75201 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLY, and WALTER ROBERTS III, on behalf of themselves and all others similarly situated, Plaintiffs, vs. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, a Virginia corporation, and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC, a Virginia corporation, Defendants. CIVIL ACTION NO. C07 0943 WHA

DECLARATION OF RYAN S. HILBERT IN SUPPORT OF PLAINTIFFS' CONSOLIDATED OPPOSITION TO DEFENDANTS' MOTIONS TO DISMISS

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DECLARATION OF RYAN S. HILBERT ISO CONSOLIDATED OPPOSITION

CASE NO. C07 0943 WHA
Dockets.Justia.com

Case 3:07-cv-00943-WHA

Document 111

Filed 08/09/2007

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

I, Ryan S. Hilbert, do hereby declare and certify as follows: 1. I have personal knowledge of the following facts, and if called as a witness, could

and would competently testify thereto. 2. I am an attorney at law, duly licensed to practice before all the courts of the State

of California, and I am an associate with the law offices of Manatt, Phelps & Phillips, LLP, attorneys of record for Plaintiffs Bernard Paul Parrish, Herbert Anthony Adderley, and Walter Roberts III, on behalf of themselves and all others similarly situated ("Plaintiffs"), in the aboveentitled action. 3. Attached hereto as Exhibit 1 is a true and correct copy of Players Inc's Responses

and Objections to Plaintiffs' First Set of Requests for Admissions dated August 1, 2007. 4. Attached hereto as Exhibit 2 is a true and correct copy of the Declaration of Gene

Upshaw in Support of Defendant's Motion for Sanctions dated April 3, 2007. 5. Attached hereto as Exhibit 3 is a true and correct copy of the "NFL PLAYERS

ASSOCIATION: Retired Player Group Licensing Authorization Form" signed by Herb Adderley on November 22, 2002, and showing an expiration date of December 31, 2005. This document was produced by Players Inc on August 1, 2007 in response to Plaintiffs' First Set of Requests for Production of Documents and Things. 6. Attached hereto as Exhibit 4 is a true and correct copy of the "NFL PLAYERS

ASSOCIATION: Retired Player Group Licensing Authorization Form" signed by Herb Adderley on May 1, 2001, and showing an expiration date of December 31, 2003. This document was produced by Players Inc on August 1, 2007 in response to Plaintiffs' First Set of Requests for Production of Documents and Things. Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that I executed this Declaration on August 9, 2007. /s/ Ryan S. Hilbert Ryan S. Hilbert
20186402.1

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DECLARATION OF RYAN S. HILBERT ISO CONSOLIDATED OPPOSITION

CASE NO. C07 0943 WHA