Parrish et al v. National Football League Players Incorporated

Filing 338

MOTION to Seal Document -- Miscellaneous Administrative Request to File Certain Confidential Materials Under Seal filed by Bernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Declaration of Ryan S. Hilbert in Support of Plaintiffs' Miscellaneous Administrative Request to File Certain Confidential Materials Under Seal, # 2 [Proposed] Order Sealing Confidential Documents)(Hilbert, Ryan) (Filed on 7/30/2008)

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

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: [e-mail] JILL ADLER (Bar No. CA 150783) E-mail: [e-mail] 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 CIVIL ACTION NO. C07 0943 WHA

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,

DECLARATION OF RYAN S. HILBERT IN SUPPORT OF PLAINTIFFS' MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE CERTAIN CONFIDENTIAL MATERIALS UNDER SEAL IN CONNECTION WITH PLAINTIFFS' JULY 30, 2008 LETTER BRIEF; AND THE DECLARATION OF LAURA M. FRANCO IN SUPPORT OF THE JULY 30, 2008 LETTER BRIEF

Defendants.
HILBERT DECLARATION CASE NO. C:07-0943 WHA

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

I, Ryan S. Hilbert, declare as follows: 1. I am an associate with Manatt, Phelps & Phillips, LLP, attorneys of record for

Plaintiff Herbert Anthony Adderley and the GLA Class in the above-captioned matter. The facts below are true and correct and within my own personal knowledge. If called on to testify to them, I could and would competently do so. 2. This Declaration pertains to the unredacted version of Plaintiffs' July 30, 2008

Letter Brief; and Exhibit A to the Declaration of Laura M. Franco In Support of the July 30, 2008 Letter Brief. 3. The above-referenced documents, information and exhibits contain information

that has been specifically designated by Defendants as "Highly Confidential ­ Attorneys Eyes Only" or "Confidential." 4. Plaintiffs have narrowly tailored their request to file the above information and

documents under seal in that they are only seeking to seal what Defendants have designated as "Highly Confidential ­ Attorneys Eyes Only" or "Confidential" information, testimony and/or documents pursuant to the parties' Stipulated Protective Order. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct and that this declaration was executed on July 30, 2008. /s/ Ryan S. Hilbert Ryan S. Hilbert

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HILBERT DECLARATION CASE NO. C:07-0943 WHA