Parrish et al v. National Football League Players Incorporated

Filing 157

MOTION to Seal filed by National Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit A (P.O. to Seal Documents))(Wetzel, Joseph) (Filed on 10/11/2007)

Parrish et al v. National Football League Players Incorporated

Doc. 157

Case 3:07-cv-00943-WHA

Document 157

Filed 10/11/2007

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Mark Malin (Bar No. 199757) [e-mail] DEWEY & LEBOUEF LLP 1950 University Avenue, Suite 500 East Palo Alto, CA 94303 Tel: [phone] Fax: [phone] Jeffrey L. Kessler (pro hac vice) [e-mail] David G. Feher (pro hac vice) [e-mail] Eamon O'Kelly (pro hac vice) [e-mail] DEWEY & LEBOUEF LLP 1301 Avenue of the Americas New York, NY 10019 Tel: [phone]; Fax: [phone] Kenneth L. Steinthal (pro hac vice) [e-mail] Claire E. Goldstein (Bar No. 237979) [e-mail] WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Tel: [phone]; Fax: [phone] Bruce S. Meyer (pro hac vice) [e-mail] WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Tel: [phone]; Fax: [phone] Attorneys for Defendants National Football League Players Association and National Football League Players Incorporated d/b/a Players Inc UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY, and WALTER ROBERTS, III, Plaintiffs, v. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a/ PLAYERS INC, Defendants.
MISCELLANEOUS ADMINISTRATIVE REQUEST PURSUANT TO CIVIL LOCAL RULES 7-11 AND 79-5 TO SEAL DOCUMENTS

Case No. C 07 0943 WHA MISCELLANEOUS ADMINISTRATIVE REQUEST PURSUANT TO CIVIL LOCAL RULES 7-11 AND 79-5 TO SEAL DOCUMENTS Date: Time: Ctrm: Judge: William H. Alsup

CASE NO. C 07 0943 WHA

Dockets.Justia.com

Case 3:07-cv-00943-WHA

Document 157

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In connection with Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint, and pursuant to Civil Local Rules 7-11 and 79-5, Defendants National Football League Players Association and National Football League Players Incorporated d/b/a Players Inc hereby move to file under seal the following documents, submitted on October 11, 2007: 1. Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); 2. Declaration of Andrew Feffer in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); a. Exhibits D through F to the Declaration of Andrew Feffer in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint; 3. Declaration of David Greenspan in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); a. Affidavit of Andrew Feffer (also submitted as Exhibit A to Declaration of David Greenspan in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint) (unredacted version); i. Exhibits A through K to the Affidavit of Andrew Feffer; b. Exhibits B through K and M through W to the Declaration of David Greenspan in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint; c. Exhibit L to the Declaration of David Greenspan in Support

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of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); Declaration of Doug Allen in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); a. Exhibits A through I to the Declaration of Doug Allen in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint; b. Exhibit J to Declaration of Doug Allen in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to File a Third Amended Complaint (unredacted version); Declaration of Joel Linzner (unredacted version); a. Exhibits A through F to the Declaration of Joel Linzner. Declaration of Warren Friss (unredacted version); and a. Exhibits A through D To the Declaration of Warren Friss. Copies of these documents have been lodged with the Clerk. As set forth in greater detail in the accompanying Declaration of Joseph R. Wetzel in Support of Miscellaneous Administrative Request to Seal Documents Pursuant to Civil Local Rules 7-11 and 79-5 to Seal Documents, these documents contain commercially and competitively sensitive information related to the Defendants' licensing business and have been designated, or are entitled to protection, as "Confidential" and/or "Highly Confidential ­ Attorneys' Eyes Only" pursuant to the terms of the Stipulated Protective Order entered in this action by the Court's Order of July 31, 2007. /// /// /// ///

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This request is narrowly tailored to seal only that material for which good cause to seal has been established. For the foregoing reasons, Defendants respectfully request that the Court grant Defendants' Miscellaneous Administrative Request Pursuant to Civil Local Rules 711 and 79-5 to Seal Documents.

Dated: October 11, 2007

WEIL, GOTSHAL & MANGES LLP By: /s/ Joseph R. Wetzel Joseph R. Wetzel (Bar No. 238008) Counsel for Defendants

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CASE NO. C 07 0943 WHA