Parrish et al v. National Football League Players Incorporated

Filing 299

Declaration in Support of 298 MOTION to Seal Defendants' Miscellaneous Administrative Motion to File Under Seal by Roy Taub filed byNational Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit Exhibit 1 to Declaration of Roy Taub in Support of Defendants' Misc Admin Motion to File Under Seal)(Related document(s) 298 ) (Padnos, Todd) (Filed on 6/13/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 299

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

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] 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] 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 ROY TAUB IN SUPPORT OF DEFENDANTS' MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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Declaration of Roy Taub

Civ. Action No. C07 0943 WHA
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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 Under Seal ("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), I attempted to contact counsel for Plaintiffs

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to determine if Plaintiffs would stipulate to the filing of certain documents submitted with Defendants' Opposition to Plaintiffs' Motion for Class Certification under seal. 3. On June 11 and June 12, 2008, I left voicemail messages for Ryan Hilbert,

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an attorney with Manatt, Phelps & Phillips, LLP, co-counsel for Plaintiffs, to call me at my office telephone number regarding this Motion. 4. On June 12, 2008, I received an e-mail from Ryan Hilbert stating that

"[b]ecause we have not seen the specific documents and/or testimony Defendants intend to file under seal ­ many, if not all, of which were unilaterally designated by Defendants as `Confidential' or `Highly Confidential ­ Attorneys' Eyes Only' ­we cannot blindly stipulate to Defendants' Request. Nor can we unequivocally state that we will not oppose such a Request (as Defendants have previously done in connection with documents submitted by Plaintiffs)." A true and correct copy of the e-mail from Ryan Hilbert to me, dated June 12, 2008, is attached hereto as Exhibit A.

Declaration of Roy Taub

Civ. Action No. C07 0943 WHA

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: June 13, 2008 _________/s/_______________ Roy Taub

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