Parrish et al v. National Football League Players Incorporated

Filing 215

MOTION to Seal Document -- Miscellaneous Administrative Request To File Certain Confidential Materials Under Seal filed by Bernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Declaration of Ryan S. Hilbert, # 2 Proposed Order)(Hilbert, Ryan) (Filed on 3/14/2008)

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MANATT, PHELPS & PHILLIPS, LLP
ATTO RNEY S AT LAW PA L O 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 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, CIVIL ACTION NO. C07 0943 WHA

DECLARATION OF RYAN S. HILBERT IN SUPPORT OF PLAINTIFFS' MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE CERTAIN CONFIDENTIAL MATERIALS UNDER SEAL IN CONNECTION WITH PLAINTIFFS' MOTION FOR CLASS CERTIFICATION AND BRIEF IN SUPPORT THEREOF

Defendants.
20198305.1 HILBERT DECLARATION CASE NO. C:07-0943 WHA

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MANATT, PHELPS & PHILLIPS, LLP
ATTO RNEY S AT LAW PA L O A L T O

I, Ryan S. Hilbert, declare as follows: 1. I am an associate with Manatt, Phelps & Phillips, LLP, attorneys of record for

Plaintiffs Bernard Paul Parrish, Herbert Anthony Adderley, and Walter Roberts, III, in the abovecaptioned matter. The facts below are true and correct and within my own personal knowledge. If called on to testify to them, I could and would competently do so. 2. This Declaration pertains to the Plaintiffs' Motion for Class Certification and Brief

in Support Thereof, and Exhibits G, I, K-V, X, Z, AA, and CC-TT to the Declaration of Jill Adler Naylor filed in support thereof. 3. The above-referenced documents, information and exhibits contain information

that has been specifically designated by Defendants as "Highly Confidential ­ Attorneys Eyes Only" or "Confidential." 4. Plaintiffs have narrowly tailored their request to file the above information and

documents under seal in that they are only seeking to seal what Defendants have designated as "Highly Confidential ­ Attorneys Eyes Only" or "Confidential" information, testimony and/or documents pursuant to the parties' Stipulated Protective Order. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct and that this declaration was executed on March 14, 2008. /s/ Ryan S. Hilbert Ryan S. Hilbert

20198305.1

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HILBERT DECLARATION CASE NO. C:07-0943 WHA