Parrish et al v. National Football League Players Incorporated

Filing 318

Declaration of Roy Taub in Support of 317 Memorandum in Opposition, Declaration of Roy Taub in Support of Defendants' Opposition to Plaintiffs' Motion to Strike the Declarations of Linda Castillon, Adam Sullins, Jason Brenner, Christine Finch and Steve Byrd filed byNational Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit)(Related document(s) 317 ) (Kessler, Jeffrey) (Filed on 7/10/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 318

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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' OPPOSITION TO PLAINTIFFS' MOTION TO STRIKE THE DECLARATIONS OF LINDA CASTILLON, ADAM SULLINS, JASON BRENNER, CHRISTINE FINCH AND STEVE BYRD

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Dewey & LeBoeuf LLP

Declaration of Roy Taub In Support of Defs.' Opp'n to Pls.' Mtn to Strike

Civ. Action No. C07 0943 WHA

Dockets.Justia.com

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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' Opposition to Plaintiffs' Motion to Strike the Declarations of Linda Castillon, Adam Sullins, Jason Brenner, Christine Finch and Steve Byrd. I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. Attached hereto as Exhibit A is a true and correct copy of the Joint Management Statement, dated June 7, 2007. 3. Attached hereto as Exhibit B is a true and correct copy of Players Inc's Initial Disclosures, dated June 7, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of Defendants' Initial Disclosures, dated June 29, 2007. 5. Attached hereto as Exhibit D is a true and correct copy of Defendants' Supplemental Disclosures, dated February 19, 2008. 6. Attached hereto as Exhibit E is a true and accurate copy of a letter from Laura Franco to David Greenspan, dated May 7, 2008. 7. Attached hereto as Exhibit F is a true and correct copy of a letter from David Greenspan to Laura Franco, dated May 9, 2008. 8. Attached hereto as Exhibit G is a true and correct copy of an email from Ron Katz to David Greenspan, dated May 13, 2008. 9. Attached hereto as Exhibit H is a true and correct copy of a letter from David Greenspan to Ron Katz, dated May 14, 2008. 10. Attached hereto as Exhibit I is a true and correct copy of a letter from Lew LeClair to David Greenspan, dated May 22, 2008.
Declaration of Roy Taub In Support of Defs.' Opp'n to Pls.' Mtn to Strike Civ. Action No. C07 0943 WHA

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Dewey & LeBoeuf LLP

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

11. Attached hereto as Exhibit J is a true and accurate copy of a letter from Noel Cohen to David Greenspan, dated May 15, 2008. 12. Attached hereto as Exhibit K is a true and correct copy of an email from David Greenspan to Jill Serena, dated May 19, 2008. 13. Attached hereto as Exhibit L is a true and correct copy of Defendants' Supplemental Disclosures, dated May 20, 2008. 14. Attached hereto as Exhibit M is a true and correct copy of a letter from David Greenspan to Lew LeClair, dated May 29, 2008. 15. Attached hereto as Exhibit N is a true and correct copy of a letter from Lew LeClair to David Greenspan, dated May 30, 2008. 16. Attached hereto as Exhibit O is a true and correct copy of a letter from David Greenspan to Lew LeClair, dated June 5, 2008. 17. Attached hereto as Exhibit P is a true and correct copy of a letter from Lew LeClair to David Greenspan, dated June 10, 2008. 18. Attached hereto as Exhibit Q is a true and correct copy of an excerpt of the transcript of the Rule 30(b)(6) deposition of Joel Linzner, dated February 8, 2008. 19. Attached hereto as Exhibit R is a true and correct copy of an excerpt of the transcript of the Rule 30(b)(6) deposition of Warren Friss, dated April 4, 2008. 20. Attached hereto as Exhibit S is a true and correct copy of an excerpt of the transcript of the Rule 30(b)(6) deposition of Adam Zucker, dated April 4, 2008. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: July 10, 2008

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Dewey & LeBoeuf LLP

_________/s/_______________ Roy Taub

-2Declaration of Roy Taub In Support of Defs.' Opp'n to Pls.' Mtn to Strike Civ. Action No. C07 0943 WHA