Parrish et al v. National Football League Players Incorporated

Filing 254

Declaration of Ronald Katz in Support of 253 Reply Memorandum, filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14)(Related document(s) 253 ) (Katz, Ronald) (Filed on 4/4/2008)

Exhibit 4 to the Declaration of Ronald Katz in Further Support of Plaintiffs' Motion for Class Certification

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DEWEY & LEBOEUF

Dewey & LeBoeuf ILLP 1301 Avenue of the Americas New York, NY 10019-6092 LLP el [phone] fax [phone] [e-mail]

January 23, 2008 BY FACSMULE
The Honorable James Larson Chief Magistrate Judge United States District Court Northern District of California Federal Building

450 Golden Gate Avenue, Fifteenth Floor San Francisco, CA 94102 Re: Parrish v. National Football League Players Association, et a L Case No. C07-0943 WHA

Dear Judge Larson,
We represent Defendants, the NFLPA and Players Inc, in the above-captioned action. I write in connection with the Court's Notice of Settlement Conference and Settlement Conference Order dated October 19, 2007 (the "Order"), to request a rescheduling of the Settlement Conference currently set for February 6, 2008 at 2:00 pm. We do not believe that there is any reasonable prospect of settlement at this arly stage in the case. Moreover, during the month of February, approximately ten key depositions will take place, and we believe that these depositions will better inform the parties about their respective positions in this litigation. Accordingly, we believe that the Settlement Conference would be much more productive if it was convened during the second half of the month of March, instead of the first week in February. Pursuant to the Order, we have consulted with Plaintiffs on this issue, and stated why we believe that the Settlement Conference should be rescheduled. Plaintiffs would not agree to rescheduling the Settlement Conference, but this does not affect our view that the Settlement Conference will be much more productive if it takes place in mid- to late- March.

We will make ourselves available to participate in a conference call to discuss these issues with Your , Honor and oounsel for Plaintiffs if the Court believes that would be helpful.

David G. Feher Counsel for Defendants cc: onald S. Katz, Esq. Lewis T. LeClair, Esq.

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