Parrish et al v. National Football League Players Incorporated

Filing 267

Letter from Jeffrey L. Kessler to The Honorable William H. Alsup. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Padnos, Todd) (Filed on 4/9/2008)

EXHIBIT 3

June 2007 Request # 1 2 3 4

Resolution Production Completed Production Completed Production Completed Revised, Rolling Production Ongoing

June 2007Request

Dec 2007/ Mar 2008 Request # 11 12 13

December 2007/March 2008 Request

All documents that refer to or constitute representations made by PLAYERS INC as to its or the [NFLPA's] licensing or representation of retired NFL players. All documents that refer to or constitute representations made by PLAYERS INC as to its or the NFLPA's exclusive licensing or exclusive representation of retired NFL players. All documents that summarize, describe or refer to communications with any NFL player concerning licensing matters.

7

5

Revised, Rolling Production Ongoing

7

6

Revised, Rolling Production Ongoing

7

8

All communications to retired players, licensees, or third-parties regarding the terms, scope or purported benefits of Defendants' group licensing programs for retired players (e.g., letters to retired players regarding the benefits of joining the Retired Players Group Licensing Program, letters to licensees regarding the terms of retired player licensing). All communications to retired players, licensees, or third-parties regarding the terms, scope or purported benefits of Defendants' group licensing programs for retired players (e.g., letters to retired players regarding the benefits of joining the Retired Players Group Licensing Program, letters to licensees regarding the terms of retired player licensing). All communications to retired players, licensees, or third-parties regarding the terms, scope or purported benefits of Defendants' group licensing programs for retired players (e.g., letters to retired players regarding the benefits of joining the Retired Players Group Licensing Program, letters to licensees regarding the terms of retired player licensing). All documents contained in files or folders designated as complaints by retired players regarding Defendants' group licensing activities.

7 8 9 10 11 12 13 14 15 16

Production Completed Production Completed Production Completed Production Completed Production Completed Production Completed Production Completed Production Completed Production Completed Production Completed

14 2, 15 2, 16 2, 17 2, 15 6 4 4 18 19

1

June 2007 Request # 17 18 19 20 21

Resolution Production Completed Production Completed Production Completed Production Completed Revised, Rolling Production Ongoing Production Completed Request Never Served, Production Completed

June 2007Request

Dec 2007/ Mar 2008 Request # 19 20 20 20

December 2007/March 2008 Request

All documents that summarize, describe or refer to the conception, drafting, creation, modification or implementation of any GLA.

21

All documents that summarize, describe or refer to the drafting or modification of any retired player GLA.

22 N/A

22 1 Documents showing all licensing income from those license agreements that contain language referencing retired players as alleged in Paragraphs 25, 26, and 28 of Plaintiffs' Third Amended Complaint. These license agreements include, but are not limited to, license agreements with EA, Topps, Upper Deck, Activa Consumer Promotions Inc., Airplay, Atari, Fanball Interactive, LLC d/b/a Fanball.com, Fathead, Inc., Flipp Sports, Fox Sports Interactive Media, LLC, Gamewear, Inc., Jamdat Mobile Inc., K2 Licensing and Promotions, Little Earth Productions, Inc., MBI, Incorporated, The Merrick Mint, Motion Imaging Inc., MVP Pics USA, LLC, National Direct, and USAOPOLY, Inc. Documents sufficient to show the actual calculation, payment or distribution of the equal share royalty referred to in the agreement between the NFLPA and Players Inc. All draft agreements, correspondence and/or communications, including but not limited to emails, between the NFLPA, Players Inc and/or the licenses [sic] identified above that relate to the negotiation, drafting or execution of the respective licensing agreements. All Players Inc Monthly Reports, Players Inc Departmental Monthly Reports and Departmental Reports from the Trading Cards and Collectibles, Multimedia, and Apparel departments of Players Inc. Players Inc and NFLPA organizational charts

N/A

N/A

Request Never Served, Production Completed Request Never Served, Production Completed Request Served March 14, Rolling Production Ongoing Request Served March 14, Rolling Production Ongoing

3

5

N/A

9

N/A

10

2