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)

EXHIBIT 1 TO DECLARATION OF ROY TAUB IN SUPPORT OF DEFENDANTS' MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Taub, Roy
From: Sent: To: Cc: Hilbert, Ryan [[e-mail]] Thursday, June 12, 2008 3:09 PM Taub, Roy Katz, Ron; Feher, David; Greenspan, David

Subject: Parrish v. NFLPA Roy: This responds to your voice mail this morning concerning Defendants' request to file documents under seal in connection with their anticipated motion for summary judgment. Because 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 Request (as Defendants have previously done in connection with documents submitted by Plaintiffs). Very truly yours, Ryan Ryan S. Hilbert Manatt, Phelps & Phillips, LLP 1001 Page Mill Road, Building 2 Palo Alto, CA 94304 Tel: [phone] Fax: [phone] CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify us by reply e-mail at [e-mail] <mailto:[e-mail]> or by telephone at [phone], and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you.

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6/13/2008