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 19

Case No. C 07 0943 WHA Parrish v. National Football League Players Association, et al.

Certified

Copy

UNITED

STATES DISTRICT

COURT

NORTHERN DISTRICT SAN FRANCISCO DIVISION BERNARD PAUL PARRISH HERBERT ANTHONY ADDERLEY and WALTER ROBERTS III
on behalf and
of themselves similarly
all others

situated

Plaintiffs

vs.

CIVIL

ACTION NO.

C07 0943

WHA

NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION
Virginia corporation

and

NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED cl/b/a PLAYERS INC.
Virginia Corporation

Defendants.

30b6

Videotaped

Deposition

of

GLENN M. EYRICH
Tuesday
February

12 2008

930

a.m.

Mannatt

Phelps

Phillips

LLP
N.W.

One Metro Center 700
Washington

12th Street D.C.

Linda Ann Crockett

Notary Public.

TO
Plaze Drive

California

9533

.2700 2717

errtral

Avenue

one

85012

Glenn

N.

Eyrich

February

12

2008

Reported Linda

by
A.

Crockett

APPEARANCES
RONALD NOEL
S. S.

KATZ
Phelps Center

ESQUIRE ESQUIRE

COHEN

Mannatt
One
700

Phillips LLP
N.W.

Metro 12th

Street
D.C.

Suite

1100 20005

Washington

650

812-1346 of the Plaintiffs

On behalf

DAVID ROY Dewey 1301 New
10 11 12 13 14 15 16 17

FEHER TAUB
Avenue

ESQUIRE

ESQUIRE LLP Americas 10019-6092

LeBoeuf
of

the York

York

New

212

259-7164 of the Defendants

On behalf

ALSO

PRESENT
Philip
G.

Rowley

Marks

Videographer

18 19
20

30b
EYRICH
recording beginning taken on
at

Deposition simultaneous February
at

of

GLENN

with

videotape

21 22 23 24 25

Tuesday
One

12

2008
Phelps 12th Linda

930 a.m.
Metro

Mannatt
700

Phillips LLP Street
Ann

Center D.C.

N.W.

Washington
Notary

before

Crockett

Public.

800.300.1214 REPORTING
LITIGATION SERVICES
WWW.PAULSONREPORTThtCOM

619.239.4111

Glenn

N.

Eyrich

February

12

2008

59

MR.

FEHER

Ill

object

to

the

prior BY MR.

question.

KATZ
Q.

And
is

according list of not from ad
EA.

to

Exhibit

89
who

Exhibit signed

90

retired hoc

players

GLAs

but

agreements you

who that

received monies

money flowed
to
A.

Were

aware players

from

EA

to

retired

pursuant
10

GLAs
Am the You supposed
to

read

this

11

Exhibit

89
Q.

letter
may read
Mr. it if

12

you can

like. double check
It

13

produced what

it

just so

Feher
is

14

Im

saying

about

these

correct.

15

doesnt

add

anything.
MR.

16

FEHER
know.

His

question

is

as

to

17

what BY

you

already

18

MR.

KATZ
Q.

19

Do

you
to

--

did

you

know

that who

monies

20

from

EA

flowed GLAs but
MR. A.
Q.

retired ad hoc

players

had

21
22

signed

not

agreements
to of

FEHER
was

Objection not your aware

the

form.

23

No

that. back the
to

24 25

Directing which
is

attention one
of

Exhibit

86

the

GLA

GLA5

P.ALJLSSON
800.300.1214 REPORTING
LITIGATiON SERVICES
WWW.PAULSONRrPORTING.coM

619.239.4111

Glenn

M.

Eyrich

February

12

2008

60

signed the
it

by Mr.
--

Adderley.
to

And

youll

notice

in

last
is

second

last paragraph it the monies

says

further by

understood that
such will licensing be divided account signed form. such
of

generated group player NFLPA

retired

player

rights and an

between for all group Are

the eligible

escrow who

members

have

licensing
of
10

authorization
of

you

aware

the

creation
MR. A.
0.

any

escrow

account
to form.

FEllER

Objection

11

No
And

Im

not.

12

directing which
is

your the
in

attention
to

again

13

to Mr.

Exhibit fluff the

87
you

letter the

14

will

note player

second

page

of

15

that

retired

group same the page

licensing appears last
87.

16

authorization
in

form the
This
is

language second
of to

17
18

the

license.
of it is

paragraph
It

the

second

Exhibit

19

says

further by

understood that
licensing be divided
of

the retired by the

20 21 22
23

monies player player

generated groups and

such will

rights

escrow who

account have

for all

eligible

NFLPA members
licensing you aware

signed

group ask you are

24

authorization.
of

Again
escrow account

25

any

such

being

800.300.1214 REPORTING
LITIGATION SERVICES

619.239.4111
WWW.PAULSONREpORnNG.COM

Glenn

M.

Eyrich

February

12

2008

61

created
MR.
A.

FEllER

Objection

to

form.

No.

Q.

And

then from

with

respect
to

to

Exhibit

88

the

monies

PhotoFile
to

retired

players with
aware of any

respect escrow

those

monies are you created
to
form.

account

being

MR. A.
10 Q.

FEllER not that

Objection

No
And

Im

aware

of.

directing are those

your

attention that

then

11

to

Exhibit

90

individuals
to

12

received
EA.

money you with

pursuant
of

GLA
escrow

money account

from being

13

Are

aware

any
to

14

created

respect
MR.

those Same
of

monies
objection. any escrow

15

FEHER
not

16

A.

Im

aware

17

account.
Q.

18

Moving which
is

back

to

the

2006 the

financial

19

statement
number on
A.

whats

exhibit

20 21 22
23

it
85.

Q.

85

thank

you.

If

we

look
is

in

the

current

liabilities says

section which
due refer
to to

Page
is

24

6032
third

it

royalties Does that

players retired

the

25

item.

800.300.1214 REPORTING
LITIGATION SERVICES
WWW.PAULSONREPORTING.COM

619.239.4111

Glenn

M.

Eyrich

February

12

2008

198

STATE COUNTY

OF MARYLAND OF BALTIMORE

Linda Public certify was
of

A.

Crockett named

Notary

the

State the

of

Maryland do hereby
GLENN

that

within

EYRICH
set

deposed and

at

the

time and been

place duly

herein sworn by

out
was

after

having by

me

interrogated

counsel.

further examination was

certify

that

the by
of

recorded

stenographically
is

me
the

and

this

transcript

true

record

proceedings. further certify were that the into by

stipulations
10 11 12 13 14 15 16 17 18 19

made

herein

entered

counsel

in

my presence. further certify that am not
of

counsel
of

to

any nor way

of

the

parties nor an employee
to

counsel
in

related interested

any
in

of

the

parties
of

nor this

any

the

outcome

action. As witness day
of

my hand

and

notarial

seal

this

13th

February
December

2008.

My

commission

expires

2008

23 24

Notary

Public

25

800.300.1214 REPORTING
LITIGATION SERVICES
WWW.PAULSONREPORUNG.COM

619.239.4111