Parrish et al v. National Football League Players Incorporated

Filing 225

MOTION to Seal Defendants' Miscellaneous Administrative Motion to File Under Seal Certain Confidential Materials Filed By Plaintiffs filed by National Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Declaration of Joel Linzer, # 2 Declaration of Gene Upshaw, # 3 Declaration of Molly Donovan, # 4 [Proposed] Order)(Padnos, Todd) (Filed on 3/20/2008)

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ASE 307CV00943WHA DOCUMENT 186 FILED 11212007 PAGE 1OF MARK MAIM BAR RNRNALINDI CORN 1950 UNIVERSITY NO 199757 DEWEY LEBOEUF LU AVENUE SUITE 500 8457333 EAST PALO ALTO CA 94303 TEL 650 8457000 KESSLER FAX 650 VICE JEFFREY PRO HAC JKESSLERDLCOM DAVID FEHER PRO HAC VICE DFEHERDJCOM EAMON OKELLY PRO HEW VICE DEWEY LEBOBUF LU 1301 EOKELLYDICOM AVENUE OF THE AMERICAS NEWYORK NY 10019 TEL 10 212 2598000 STEINTHAL FAX 212 2596333 KENNETH CLAIRE PRO HAC CORN VICE KENNETHSTEINTHALWEIL 11 GOLDSTEIN BAR NO 237979 CLAIREGOLDSTEIN 12 13 201 WEIL CORN WELL GOTSHAL MANGES LU REDWOODSHORES PARKWAY REDWOOD HORES CA 94065 S TEL 650 8023000 FAX 650 8023100 MEYER PRO HAC VICE BRUCEMEYERWEILCOM MANGES WELL GOTSIIAL BRUCE 14 LU 16 767FIFTHAVENUE NEWYORKNY 17 18 19 10153 TEL 212 3108000 FAX 2123108007 ATTORNEYS FOR DEFENDANTS NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION AND NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED DBA PLAYERS INC 20 21 22 23 PLAINTIFFS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BERNARD PAUL PARRISH HERBERT ANTHONY ADDERLEY WALTER ROBERTS III CASE NO 07 0943 WHA 24 25 26 27 28 NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION AND NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED DBA PLAYERS INC DEFENDANTS DECLARATION OF JOEL LINZNER IN SUPPORT OF DEFENDANTS MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL CERTAIN CONFIDENTIAL MATERIALS FILED BY PLAINT WFS DECLARATION OF JOEL LINZNER IN SUPPORT FILE CIV ACTION NO C07 0943 WHA OF DEFENDANTS MOTION TO UNDER SEAL CASE 307CV00943WHA DOCUMENT 186 FILED 11212007 PAGE OF UNITED NORTHERN DISTRICT STATES DISTRICT COURT OF CALIFORNIA SAN FRKNCISCO DIVISION BERNARD PARRISH ET AL CASE PLAINTIFFS NO 07 0943 WHA NATIONAL CI FOOTBALL LEAGUE PLAYERS ASSOCIATION AL DEFENDANTS DECLARATION OF JOEL LINZNER JOEL LINZNER DECLARE AS FOLLOWS AM EXECUTIVE ELECTRONIC ARTS INC VICE PRESIDENT OF BUSINESS SINCE APRIL AND LEOAL AFFAIRS OF EA AND HAVE HELD THAT POSITION PRESIDENT 2004 FROM OCTOBER AFFAIRS 2002 JULY TO APRIL 2004 WAS SENIOR VICE WAS VICE THE OF WORLDWIDE BUSINESS OF WORLDWIDE BUSINESS RESPONSIBLE FROM AT 1999 JULY TO OCTOBER 2002 PRESIDENT AFFAIRS EA WITH SINCE 1999 HAVE BEEN EA PERSON PRINCIPALLY FOR NEGOTIATIONS NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED JIBA PLAYERS INC PLAYERS MC REGARDING PLAYER GROUP LICENSING AM OVER TWENTYONE YEARS OF AGE AND HAVE PERSONAL IF KNOWLEDGE OF EACH OF THE TESTIFY FACTS STATED HEREIN CALLED UPON TO TESTIFY COULD AND WOULD COMPLETELY THERETO ACTION HAVE ATTACHED TO THEIR UNDERSTAND THAT PLAINTIFFS THIRD IN THIS AMENDED COMPLAINT CERTAIN LICENSING CONTRACTS BETWEEN EA AND PLAYERS 2005 MC SPECIFICALLY THE CONTRACTS EFFECTIVE AS OF MARCH 2004 AND MARCH EA SENSITIVE LICENSING CONTRACTS THE EA LICENSING CONTRACTS ARE FILLED WITH EXTREMELY CONFIDENTIAL BUSINESS INFORMATION INCLUDING SPECIFIC PRICE TERMS ROYALTY RATES AND OTHER THIS INFORMATION NOT INDIVIDUALLY NEGOTIDTED TERMS AND CONDITIONS OF THE CONTRACTS IS CASE 307CV00943WHA DOCUMENT 186 FILED 11212007 PAGE OF MATTER OF PUBLIC RECORD AND WOULD CAUSE SUBSTANTIAL COMPETITIVE INDEED BELIEVE THAT PUBLIC INJURY TO LA IF IT WERE PUBLICLY DISCLOSED DISCLOSURE OF THIS INFORMATION WOULD HARM CON BY DIVULGING THAT TO EAS AND PLAYERS INCS COMPETITORS THE CONFIDENTIAL PRICE AND OTHER TERMS EA AND PLAYERS INC NCGOTIATED IN THESE CONTRACTS THE HARM TO EA AND OTHCRS FROM PUBLIC DISCLOSURE OF THCSE DOCUMENTS WOULD BE SEVERE AND IMMEDIATE DECLARE UNDER THE PENALTY OF PERJURY UNDER THE LAWS OF THE UNITED STATES OF AMERICA DECLARATION AND THE STATE WAS IN OF CALIFORNIA IN THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS EXECUTED REDWOODCITY CALIFORNIA ON NOVEMBER 21 2007 OELLI NC

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