Parrish et al v. National Football League Players Incorporated
Filing
385
Declaration of Jeffrey Kessler in Support of 384 Letter Dated August 1, 2008 filed byNational Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19)(Related document(s) 384 ) (Padnos, Todd) (Filed on 8/25/2008)
EXHIBIT 16
Case No. C 07 0943 WHA Parrish v. National Football League Players Association, et al.
PAGE
BERNARD PARRISH
CONFIDENTIAL
IN
THE UNITED
STATES
DISTRICT
COURT
FOR THE NORTHERN DISTRICT SAN FRANCISCO BERNARD PAUL PARRISH HERBERT ANTHONY ADDERLEY AND WALTER ROBERTS
ON BEHALF OF
OF CALIFORNIA
DIVISION
III
THEMSELVES
AND ALL
OTHERS SIMILARLY
SITUATED PLAINTIFFS
CIVIL ACTION
NO C070943WHA
NATIONAL PLAYERS
10
FOOTBALL
LEAGUE
ASSOCIATION
CORPORATION FOOTBALL AND
VIRGINIA NATIONAL
PLAYERS
11
INC
DBA
PLAYERS
INC
VIRGINIA
12
CORPORATION DEFENDANTS
13 14 15 16 17 18 19 20
VIDEOTAPED
DEPOSITION
OF BERNARD PAUL PARRISH
THURSDAY MARCH 13
2008
21
22
REPORTED JOB
BY
LORI
GOODIN MACKENZIE
RPRCLR
NO
200716
ESQUIRE
DEPOSITION
18009449454
SERVICES
PAGE
BERNARD PARRISH
CONFIDENTIAL
THE PARRISH
DEPOSITION
OF BERNARD PAUL
WAS CONVENED ON THURSDAY
MARCH 13
OFFICES
2008
COMMENCING AT LEBOEUF BEFORE LORI
PROFESSIONAL 975
916
AM
STREET
AT THE
OF DEWEY
NW WASHINGTON DC
REGISTERED
LIVENOTE THE STATE OF
GOODIN MACKENZIE REPORTER
CERTIFIED
FOR
REPORTER
AND NOTARY PUBLIC
MARYLAND
10 11 12 13 14 15 16 17 18 19 20 21 22
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE
BERNARD PARRISH
CONFIDENTIAL APPEARANCES
FOR PLAINTIFFS RONALD
KATZ
PHELPS
ESQUIRE
MANATT
1001 PALO
PHILLIPS
LLP
PAGE MILL
ROAD BUILDING
94304
ALTO
CALIFORNIA
6508121346
RKATZRNANATT
10 11
12 13
CORN
AND NOEL
COHEN ESQUIRE
PHELPS
MANATT
11355
PHILLIPS
LLP
14 15
16 17 18 19
WEST OLYMPIC
BOULEVARD
90064
LOS ANGELES
CALIFORNIA
3103124388
NCOHENMANATT
CORN
20 21
22
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE
BERNARD PARRISH
CONFIDENTIAL APPEARANCES
CONTINUED
FOR DEFENDANTS JEFFREY ROY TAUB DEWEY
1301
KESSLER
ESQUIRE LEBOEUF
THE
ESQUIRE
AVENUE OF
AMERICAS
NEW YORK NEW YORK
100196092
2122597394
10 11 12 13 14 15 16 17 18 19 20 21 22
JKESSLERDLCOM RTAUBDLCOM
ALSO PRESENT
TJ
OTOOLE VIDEOGRAPHER
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE 197
BERNARD PARRISH
CONFIDENTIAL
THAT TOLD
REALLY
ISNT
SAID
YOU KNOW
DO YOU HAVE ANY
THEM ABOUT
THE
SUIT
SPECIFICS
WITH REGARD TO THE PLAYERS
LICENSING
OR
WITH
AND
REGARD TO THE
HERB
INC
AND
HAD THE MOST INTEREST
DIRECT
AND THE MOST SPECIFIC
HE HAD BEEN
INFORMATION INVOLVED
INFORMATION
IN
DISCUSSED
IT
WITH
SAM
HUFF
SAM ALMOST REDSKINS
DISCUSSED
10 11 12 13 14 15 16 17 18 19 20 21 22
IT
WITH
NUMBER OF PEOPLE
AN ANNOUNCER FOR THE LIKE THAT
JOINED
AND WE
BUT HES
DIDNT
FEEL
WOULD BE GOOD FOR
HIM
PARTICULARLY
SO WHEN YOU
WHAT DID YOU TELL
SPOKE
TO
MR ADDERLEY
HIM WAS THE PURPOSE OF THIS
LAWSUIT
MR KATZ
READ THE QUESTION
IM
SORRY
COULD YOU
BACK
PLEASE
RECORD READ
BY
MR KESSLER
BEFORE WHEN YOU FIRST
APPROACHED
HIM ABOUT
IT
WHEN
FIRST
TALKED TO HIM
THE
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE 198
BERNARD PARRISH
CONFIDENTIAL
PURPOSE WAS TO FIND HAPPENING
AND THAT
SO
OUT
THE
TRUTH
ABOUT
WHAT WAS
WITH
THE
MONEY FROM THE ENDORSEMENTS MADDEN VIDEO
GAMES AND ALL OF
FORTH
OF THE
SORT OF
THING
AND OUR TOPPS TRADING
OUT THE CARDS TRUTH AND ALL ABOUT
OF
THE
YOU KNOW TO FIND PLAYERS
INCOME
WHAT THE
ASSOCIATION
FROM
WAS DOING
WITH OUR
LIKE
WITH THE
WAS
10 11 12 13 14 15 16 17 18 19 20 21 22 IT
IT
WHICH WE FELT RETIRED
SHOULD
BE GOING TO THE
PLAYERS
AND
WAS
NOT
DID YOU TELL RETIRED HIM
THAT
YOU THOUGHT WITHOUT
THEY WERE USING PAYING
FOR
PLAYER RIGHTS
THOSE RIGHTS
YES
OKAY
IDENTIFY
RIGHTS TO
DID
HE
AGREED
YOU YOUR
AND WHAT PRODUCTS DID
MR
ADDERLEY WHERE YOU THOUGHT
WERE BEING
UTILIZED
BUT YOU WERENT BEING
PAID MR KATZ
THE BROUGHT
OBJECT
IN
WITNESS
PARTICULAR
IN
UP MADDEN VIDEO
GAMES
WHICH BOTH THE
ARE
CLEVELAND BROWNS AND THE PACKERS
MENTIONED IN
ESQUIRE
DEPOSITION
18009449454
SERVICES
PAGE 199
BERNARD PARRISH
CONFIDENTIAL
THE
VINTAGE
2005
ISSUE
OF
THAT
OF THE TEAMS
VIDEO ARE
GAME IN
IT
AND WHICH
THE
BROWNS 1964 OR
AND 65
AND THE
1965
66
PACKERS
WERE IN HAD
IT
AND HERB AND
ABOUT
DISCUSSION
HE
OF
THAT
AND THAT
WAS SOMETHING
SAID
HELL
IVE
NEVER GOTTEN
SAID
ANYTHING
OUT
IT
IVE
NEVER GOTTEN ANYTHING
OUT BY
10 11 12 13 14 15 16 17 18 19
OF
IT
DONT KNOW ANYBODY WHO HAS
MR KESSLER
YOUR NAME IS NOT INCLUDED
IN THAT
VIDEO
GAME IS
IT
YOUR NAME
IS
MY IDENTITY
IN
THERE
WITHOUT MY
NAME YES OKAY
UNDERSTAND YOU PLAYED ON THAT WITH
TEAM
ME
YOUR NAMES NOT THERE
IS
IT
QUESTION
MR KATZ
OBJECT
JUST
ANSWER THE
YOU MAY ANSWER
THE
20
21 22
WITNESS
EXCUSE
ME
BY
MR KESSLER
IS
YOUR NAME IN
THE
GAME YES OR
NO
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE 200
BERNARD PARRISH
CONFIDENTIAL
YOU
KNOW
DONT
HAVE
THE
GAME
MY
GRANDSON HAS IT
OKAY
HE WAS IDENTIFIED COULD LEAGUE IDENTIFY AND
SAYS
GRANDPA
POINT
YOU RE IN THAT
IT
SO
TO THE ME BY AS
MY GRANDSON
YEARS IN THE
HEIGHT
WEIGHT
RATING
CORNERBACK
OKAY
SO HE
10 11 12 13 14 15 16 17 18 19 20 21 22
DIDNT
HAVE THAT
ANY TROUBLE ALLOWED IN
AND
THE
THE
NUMBERS THAT
ARE
WERE
GAME INCLUDED
MY NUMBER AND NOT OTHER NUMBERS
SO HE ASSUMED THAT THAT WAS
GRANDPA
AND
DID PLAY
FOR THE
64 BROWNS
NOT
OKAY RIGHT
YES OR
YOUR NAME IS
THERE
NO PLEASE
HAVENT
SEEN
DONT KNOW
MY GRANDSON SAW IT
IT
OKAY
COMPLAINTS
THAT
YOU REVIEWED ALL
IN THIS
OF THE
WERE FILED
CASE
BEFORE
THEY WERE FILED
YES
HAVE
ESQUIRE DEPOSITION
18009449454
SERVICES
PAGE 425
BERNARD PARRISH
CONFIDENTIAL
CERTIFICATE UNITED DISTRICT
STATES OF OF COURT
REPORTER
AJMTERICA
OF COLUNBIA LORI
MACKENZIE
THE
REPORTER BEFORE
DO
WHOM THE
FOREGOING DEPOSITION
THAT THE
WAS TAKEN
HEREBY CERTIFY
APPEARS IN THE
WITNESS WHOSE TESTIMONY
WAS SWORN BY
FOREGOING DEPOSITION
OF SAID
ME
THAT
THE
TESTIMONY
WITNESS WAS TAKEN
BY ME IN
10 11 12 13 14 15 16 17 18 19 20
MACHINE SHORTHAND AND THEREAFTER BY COMPUTERAIDED
IS
TRANSCRIBED
SAID
TRANSCRIPTION
THAT
DEPOSITION
BY SAID
TRUE
RECORD OF THE
AM NEITHER
TESTIMONY
COUNSEL
GIVEN
WITNESS
THAT
FOR RELATED TO NOR EMPLOYED BY ANY OF THE
PARTIES WAS TO THE
ACTION
IN
WHICH THIS
THAT
DEPOSITION
RELATIVE
TAKEN
AND
FURTHER
AM NOT
OR EMPLOYEE BY THE
OF ANY ATTORNEY OR COUNSEL
EMPLOYED
OR
PARTIES
HERETO OR FINANCIALLY
IN THE OUTCOME
OTHERWISE
INTERESTED
OF THIS
ACTION
LORI
21
MACKENZIE
IN
NOTARY PUBLIC
DISTRICT
OF
AND FOR THE
COLUMBIA
22
MY COMMISSION
EXPIRES
APRIL
14
2011
ESQUIRE DEPOSITION
18009449454
SERVICES
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