Parrish et al v. National Football League Players Incorporated

Filing 309

Declaration of Brett Charhon in Support of 308 MOTION to Strike the Declarations of Linda Castillon, Adam Sullins, Jason Brenner, Christine Finch and Steve Byrd Filed in Support of Defendants' Motion for Summary Judgment filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P)(Related document(s) 308 ) (Hilbert, Ryan) (Filed on 7/1/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 309

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A PROFESSIONAL CORPORATION · ATTORNEYS

MANATT, PHELPS & PHILLIPS, LLP RONALD S. KATZ (Bar No. CA 085713) E-mail: [e-mail] RYAN S. HILBERT (California Bar No. 210549) E-mail: [e-mail] NOEL S. COHEN (California Bar No. 219645) E-mail: [e-mail] 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: [phone] Facsimile: [phone] McKOOL SMITH, P.C. LEWIS T. LECLAIR (Bar No. CA 077136) E-mail: lleclair@mckoolsmith 300 Crescent Court, Suite 1500 Dallas, TX 75201 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY, and WALTER ROBERTS, III on behalf of themselves and all others similarly situated, Plaintiffs vs. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, a Virginia corporation, and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC, a Virginia corporation, Defendants. CIVIL ACTION NO. C07 0943 WHA DECLARATION OF BRETT CHARHON IN SUPPORT OF PLAINTIFFS' MOTION TO STRIKE

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DALLAS, TEXAS

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DECLARATION OF BRETT CHARHON IN SUPPORT OF PLAINTIFFS' MOTION TO STRIKE ­ Page 1 Civil Action No. C07 0943 WHA

Dockets.Justia.com

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A PROFESSIONAL CORPORATION · ATTORNEYS

I, Brett Charhon, declare as follows: 1. I am an attorney with McKool Smith, P.C., counsel for Plaintiff Herbert Anthony

Adderley and the GLA Class in this matter. I have personal knowledge of the matters stated herein. 2. Attached hereto as Exhibit A is a true and correct copy of a Joint Management

Statement, dated June 7, 2007. 3. Attached hereto as Exhibit B is a true and correct copy of Defendant Players

Inc's Initial Disclosures Pursuant to Fed. R. Civ. P. 26(a)(1), dated June 7, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of Initial Disclosures of

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Defendants NFLPA and Players Inc Pursuant to Fed. R. Civ. P. 26 (a)(1), dated June 29, 2007. 5. Attached hereto as Exhibit D is a true and correct copy of a Notice of Deposition

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of Patricia Allen, dated August 6, 2007. 6. Attached hereto as Exhibit E is a true and correct copy of a Subpoena to Topps

Company, Inc., dated January 4, 2008. 7. Attached hereto as Exhibit F is a true and correct copy of Defendants'

Supplemental Disclosures Pursuant to Fed. R. Civ. P. 26(a)(1), dated February 19, 2008. 8. Attached hereto as Exhibit G is a true and correct copy of a letter dated May 7,

2008 from Laura Franco to David Greenspan. 9. Attached hereto as Exhibit H is a true and correct copy of a letter dated May 9,

2008 from David Greenspan to Laura Franco.

DECLARATION OF BRETT CHARHON IN SUPPORT OF PLAINTIFFS' MOTION TO STRIKE ­ Page 2 Civil Action No. C07 0943 WHA

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A PROFESSIONAL CORPORATION · ATTORNEYS

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Attached hereto as Exhibit I is a true and correct copy of Defendants'

Supplemental Disclosures Pursuant to Fed. R. Civ. P. 26(a)(1), dated May 9, 2008. 11. Attached hereto as Exhibit J is a true and correct copy of an email, dated May 13,

2008, from Ron Katz to David Greenspan and Laura Franco. 12. Attached hereto as Exhibit K is a true and correct copy of a letter dated May 22,

2008 from Lewis LeClair to David Greenspan. 13. Attached hereto as Exhibit L is a true and correct copy of a letter dated May 14,

2008 from David Greenspan to Ron Katz. 14. Attached hereto as Exhibit M is a true and correct copy of a Notice of Deposition

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DALLAS, TEXAS

of Howard Skall, dated August 6, 2007. 15. Attached hereto as Exhibit N is a true and correct copy of a letter dated May 30,

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2008 from Lewis LeClair to David Greenspan. 16. Attached hereto as Exhibit O is a true and correct copy of a letter dated June 10,

2008 from Lewis LeClair to David Greenspan. 17. Attached hereto as Exhibit P is a true and correct copy of Defendants'

Supplemental Disclosures Pursuant to Fed. R. Civ. P. 26(a)(1), dated May 20, 2008. I declare under penalty of perjury and the laws of the United States that the foregoing is true and correct and that this declaration was executed on July 1, 2008, in Dallas, Texas. /s/ Brett Charhon____________ Brett Charhon Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Ryan S. Hilbert hereby attests that concurrence in the filing of this document has been obtained.
20203354.1 DECLARATION OF BRETT CHARHON IN SUPPORT OF PLAINTIFFS' MOTION TO STRIKE ­ Page 3 Civil Action No. C07 0943 WHA