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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One Embarcadero Center, Suite 400 San Francisco, CA 94111

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Todd Padnos (Bar No. 208202) [e-mail] DEWEY & LEBOEUF LLP One Embarcadero Center, Suite 400 San Francisco, CA 94111 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] David Greenspan (pro hac vice) [e-mail] DEWEY & LEBOEUF 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, WALTER ROBERTS III, Plaintiffs, v. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a/ PLAYERS INC, Defendants. Case No. C 07 0943 WHA DECLARATION OF MOLLY DONOVAN IN SUPPORT OF DEFENDANTS' MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL CERTAIN CONFIDENTIAL INFORMATION FILED BY PLAINTIFFS

Dewey & LeBoeuf LLP

Declaration of Molly Donovan

Civ. Action No. C07 0943 WHA

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1950 University Avenue, Suite 500 East Palo Alto, California 94303-2225

DECLARATION OF MOLLY DONOVAN I, Molly Donovan, hereby declare as follows: 1. I am an attorney with Dewey & LeBoeuf LLP, attorneys for Defendants

National Football League Players Association ("NFLPA") and National Football League Players Incorporated d/b/a Players Inc ("Players Inc") in this action. I am a member of the bar of the State of New York and my pro hac vice application in this matter was granted by the Court on August 3, 2007. I make this Declaration in support of Defendants' Defendants' Miscellaneous Administrative Motion to File Under Seal Certain Confidential Information Filed by Plaintiffs. I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. On March 20, 2008, I made efforts to obtain an oral stipulation from

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Dewey & LeBoeuf LLP

Plaintiffs with respect to Defendants' Motion to File Under Seal pursuant to Local Rule 7-11. 3. Specifically, at or around 1:45 p.m. Eastern time, I telephoned the offices

of Manatt, Phelps, & Phillips, LLP ("Manatt"), but I was unable to reach Ronald Katz, Ryan Hilbert, or Noel Cohen. 4. At or around the same time I also telephoned the Dallas offices of McKool

Smith, P.C., but I was unable to reach Jill Adler Naylor. 6. Although I was not able to obtain an oral stipulation specifically with

respect to Defendants' Motion to File Under Seal, Plaintiffs have already stipulated that the documents at issue should be filed under seal by virtue of their prior motion seeking such relief from the Court. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: March 20, 2008 _________/s/Molly Donovan____________ Molly Donovan

Declaration of Molly Donovan

Civ. Action No. C07 0943 WHA