Parrish et al v. National Football League Players Incorporated

Filing 265

Declaration of Roy Taub in Support of 264 MOTION for Leave to File A Supplemental Memorandum on Plaintiffs' Class Certification Motion filed byNational Football League Players Incorporated, National Football League Players Association. (Related document(s) 264 ) (Padnos, Todd) (Filed on 4/8/2008)

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Parrish et al v. National Football League Players Incorporated Doc. 265 1 2 3 4 5 6 7 8 9 10 One Embarcadero Center, Suite 400 San Francisco, CA 94111 Todd Padnos (Bar No. 208202) tpadnos@dl.com DEWEY & LEBOEUF LLP One Embarcadero Center, Suite 400 San Francisco, CA 94111 Tel: (415) 951-1100; Fax: (415) 951-1180 Jeffrey L. Kessler (pro hac vice) jkessler@dl.com David G. Feher (pro hac vice) dfeher@dl.com David Greenspan (pro hac vice) dgreenspan@dl.com DEWEY & LEBOEUF LLP 1301 Avenue of the Americas New York, NY 10019 Tel: (212) 259-8000; Fax: (212) 259-6333 Kenneth L. Steinthal (pro hac vice) kenneth.steinthal@weil.com WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Tel: (650) 802-3000; Fax: (650) 802-3100 Bruce S. Meyer (pro hac vice) bruce.meyer@weil.com WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Tel: (212) 310-8000; Fax: (212) 310-8007 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 ROY TAUB IN SUPPORT OF DEFENDANTS' MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE A SUPPLEMENTAL MEMORANDUM 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dewey & LeBoeuf LLP Declaration of Roy Taub in Support of Defendants' Miscellaneous Administrative Motion to File a Supplemental Memorandum Civ. Action No. C07 0943 WHA Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 One Embarcadero Center, Suite 400 San Francisco, CA 94111 DECLARATION OF ROY TAUB I, Roy Taub, 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 am admitted to practice before this Court pro hac vice. I make this Declaration in support of Defendants' Miscellaneous Administrative Motion to File a Supplemental Memorandum ("Motion"). I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. Pursuant to Civ. L.R. 7-11(a), my colleague David G. Feher and I 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 attempted to contact counsel for Plaintiffs to determine if Plaintiffs would stipulate to the filing of the proposed supplemental memorandum attached to Defendants' Motion as Exhibit A. 3. On April 7, 2008, we spoke with Noel Cohen, an attorney with Manatt, Dewey & LeBoeuf LLP Phelps & Phillips, LLP, co-counsel for Plaintiffs. Mr. Cohen informed us that he would discuss Defendants' request with his colleagues and would respond later that day. 4. Later that day, we received a letter via e-mail from Mr. Cohen, in which Plaintiffs declined Defendants' request to stipulate to the filing of a supplemental memorandum. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: April 8, 2008 _________/s/_______________ Roy Taub Declaration of Roy Taub in Support of Defendants' Miscellaneous Administrative Motion to File a Supplemental Memorandum Civ. Action No. C07 0943 WHA

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