Parrish et al v. National Football League Players Incorporated

Filing 197

Declaration of Ryan S. Hilbert in Support of 196 MOTION Miscellaneous Administrative Request to Reset Dates and Deadlines filed byBernard Paul Parrish, Herbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 196 ) (Hilbert, Ryan) (Filed on 12/3/2007)

Parrish et al v. National Football League Players Incorporated

Doc. 197

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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 (Bar No. CA 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 ADLER (Bar No. CA 150783) E-mail: [e-mail] 300 Crescent Court, Suite 1500 Dallas, TX 75201 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CIVIL ACTION NO. C07 0943 WHA

BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY, 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,

DECLARATION OF RYAN S. HILBERT IN SUPPORT OF PLAINTIFFS' MISCELLANEOUS ADMINISTRATIVE REQUEST TO RE-SET DATES AND DEADLINES

[N.D. LOCAL RULE 7-11]

Defendants.

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MISC. REQUEST RE-SETTING DEADLINES CASE NO C:07-0943 WHA

Dockets.Justia.com

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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. 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 in the above-entitled action. 2. Attached hereto as Exhibit A is a true and correct copy of a letter I sent to counsel

for Defendants on November 21, 2007. 3. Attached hereto as Exhibit B is a true and correct printout of an e-mail string

showing communications sent and received in November and December 2007 between me and David Feher, counsel for Defendants. 4. Attached hereto as Exhibit C are true and correct copies of draft Joint Stipulations

I sent to opposing counsel on November 27, 2007 and November 29, 2007, respectively. These Joint Stipulations are identical, except that the November 27 Joint Stipulation lists Defendants' originally-proposed May 30, 2008 deadline for Plaintiffs' Motion for Class Certification, and the November 29 Joint Stipulation lists Defendants' mid-March deadline. 5. As the attached exhibits demonstrate, the parties were able to agree on all of the

new dates listed in Plaintiffs' accompanying motion except the deadline for Plaintiffs' Motion for Class Certification. After exchanging several lengthy e-mails on the subject, it became clear that Defendants would not stipulate to the filing of the present motion. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on December 3, 2007. /s/Ryan S. Hilbert_______________ Ryan S. Hilbert

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MISC. REQUEST RE-SETTING DEADLINES CASE NO C:07-0943 WHA