Parrish et al v. National Football League Players Incorporated

Filing 350

Declaration of Roy Taub in Support of 349 MOTION for Leave to File Defendants' Miscellaneous Administrative Motion for Leave to File a Supplemental Declaration in Support of Their August 1, 2008 Reply Letter Brief filed byNational Football League Players Incorporated, National Football League Players Association. (Related document(s) 349 ) (Feher, David) (Filed on 8/4/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 350

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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 A SUPPLEMENTAL DECLARATION IN SUPPORT OF THEIR AUGUST 1, 2008 REPLY LETTER BRIEF

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Dewey & LeBoeuf LLP

Declaration of Roy Taub in Support of Defendants' Miscellaneous Administrative Motion to File a Supplemental Declaration

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' Miscellaneous Administrative Motion to File a Supplemental Memorandum in Support of Their August 1, 2008 Reply Letter Brief ("Motion"). I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. On Friday, August 1, 2008, Defendants submitted their August 1, 2008

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Dewey & LeBoeuf LLP

Reply Letter Brief. On that same day, Plaintiffs filed a miscellaneous administrative request for leave to file a proposed supplemental declaration concerning the parties' agreement on prestatute of limitation documents. 3. To provide the full context regarding the parties' agreement on pre-statute

of limitations documents and to correct any mistaken assertions in Plaintiffs' proposed supplemental declaration, Defendants submit their Miscellaneous Administrative Motion for Leave to File a Supplemental Declaration in Support of Their August 1, 2008 Reply Letter Brief. 4. Earlier today my colleague Jason Clark and I attempted to contact counsel

for Plaintiffs by telephone to seek a stipulation to file the proposed supplemental declaration. We were unable to speak with Laura Franco or Ryan Hilbert (with whom we left voicemail messages) or Ron Katz, whose secretary informed us that he is currently out of the country. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: August 4, 2008 _________/s/_______________ Roy Taub

Declaration of Roy Taub in Support of Defendants' Miscellaneous Administrative Motion to File a Supplemental Declaration

Civ. Action No. C07 0943 WHA