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 6
Case No. C 07 0943 WHA Parrish v. National Football League Players Association, et al.
HIGHLY UNITED STATES DISTRICT
CONFIDENTIAL COURT
SOUTHERN BERNARD
DISTRICT
PAUL
OF NEW YORK
ET
PARRISH
AL
PLAINTIFFS
AGAINST
NATIONAL FOOTBALL
ET
LEAGUE
PLAYERS
HIGHLY CONFIDENTIAL
ASSOCIATION
AL
DEFENDANTS
CASE
10 11 12 13 14
NO
C07
0943
WHA
399 PARK AVENUE NEW YORK NEW YORK
APRIL
15 16 17 18 19 20 21 22 23 24 25
904
AM
2008
DEPOSITION
OF
ADAM ZUCKER
PURSUART NOTARY
TO
SUBPOENA
OF THE
BEFORE SOPHIE
OF
NOLAN
PUBLIC
STATE
NEW YORK
ELLEN
126
GRAUER COURT REPORTING CO LLC EAST 56TH STREET FIFTH FLOOR NEW YORK NEW YORK 10022
212
7506434
REF
87185A
APPEARANCES
MOKOOL SMITH ATTORNEYS
300 FOR
PLAINTIFF
CRESCENT TEXAS
COURT
75201
SUITE
1500
DALLAS
BY
LEWIS BRETT
PHONE
LECLAIR CHARHON
ESQ
ESQ
2149784984 2149784044
LLECLAIRMCKOOLSMITH
CORN
10 11 12 13
14
FAX
EMAIL
DEWEY
LEBOEUF
FOR
LLP
15 16 17
18
ATTORNEYS
1301
DEFENDANTS
OF
AVENUE
THE
AMERICAS
NEW YORK
NEW YORK
100196092
BY
DAVID
IAN
GREENSPAN
ESQ
19 20 21 22 23 24 25
PAPENDICK 212259 212259
ESQ
6438 6333
PHONE
FAX
EMAIL
DGREENSPAN
APPEARANCES
INGRAM YUZEK GAINEN
CONTD
BERTOLOTT
LLP
CARROLL
ATTORNEYS
250
FOR NONPARTY PARK
WITNESS
AVENUE NEW YORK
10177
NEW YORK
BY
DAVID MIOKO PHONE
EBERT TAJIKA
212
ESQ
ESQ
9079603
10 11
12
FAX
2129079681
DEBERTINGRAMLLPCOM
EMAIL
13
14
ALSO
PRESENT
JOHN
15 16 17 18 19 20 21 22 23 24 25
MARTUCCI
LEGAL
VIDEOGRAPHER
77
ZUCKER CONTACTING THIRD
HIGHLY
CONFIDENTIAL
PARTIES
GOING THROUGH PLAYERS
WITHOUT
INC
MR EBERT
QUESTION OBJECTION
IS
THAT
MR LECLAIR MR EBERT
QUESTION
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
YES
OBJECT
TO
THAT
MR LECLAIR
REPHRASE
DID
ALL
RIGHT
ILL
IT
YOU JOB TELL OF
PLAYERS
NOT
INC
THAT
YOU
WOULD DO PARTIES
BETTER WITHOUT
CONTACTING
THIRD
GOING
THROUGH PLAYERS OBJECTION
TO THIS WENT
INC
TO
MR GREENSPAN
THINK
WE SAID THAT WE APOLOGIZE
FORM
PURSUANT
EXAMPLE
CLOWN
FOR HOW THIS DO
AND
NEXT
TIME
IF
WELL
YOU
BETTER
JOB
AN
WANTED TO GET
YOU
ACTIVE
HAVE
TO
PLAYER
GO GET
TO
SIGN
AUTOGRAPHS DID
ALSO
AN
AGREEMENT TO DO THAT
WHAT DO YOU
IN
PLEASE
CLARIFY
THAT
SURE
TO AND
OTHER WORDS
IM
TRYING
UNDERSTAND RERIRED
THE
DIFFERENCES
IN
BETWEEN ACTIVE
PLAYERS
TERMS OF
TOPPS
78
ZUCKER
HIGHLY
CONFIDENTIAL
AGREEMENTS OKAY
OR
HIGHLIGHT
AGREEMENTS
AUTO AGREEMENTS
MR EBERT
THINK
SAY
LETS
OBJECTION
WHEN YOU WITNESS
IS
YOURE MISCHARACTERIZING AUTO AGREEMENTS
THAT THE
CLEAR
THESE
AND
AGREEMENTS ARE MORE THAN
KEEP
AUTOGRAPHS
10 11 12 13
14
YOU
TRYING
TO
SAY
ITS
AN
AUTOGRAPH OBJECT
ON IT
AGREEMENT
THAT
BASIS
AND
ASK
IF
YOU YOU
TO
CHARACTERIZE
MORE PROPERLY
WOULD
HAVE YOU
REFERRED
TO
THEM GS AUTO
15 16
17 18
AGREEMENTS
NO
YOU
NEVER
REFERRED
TO
THEM AS
AUTO
AGREEMENTS
MIGHT
YOU HAVE
19 20 21 22 23 24 25
REFERRED MIGHT
TO
THAT TO
KNOW TO AN AGREEMENT
QOT
OF
TALK
SOMEBODY HEY
BUT MY
THE AN
AUTOQRAPH AQREEMENT AGREEMENT THAT
IS
DEFINITION
HAVE
WITH
THE
PLAYERS
DEPARTMENT
AND
INC
THAT THAT
THAT
FACILITATED
THROUGH HIGHLIGHT FROM
OVERSEE
ITS
AGREEMENT
COULD INCLUDE
ANYTHING
79
ZIIICKER
HIGHLY
CONFIDENTIAL AUTOGRAPHS
TO
AUTOGRAPHS YOU KNOW CONTRACTING
CONTRACTING PACKAGING
RIGHTS
FOR
AD
RIGHTS
AN
APPEARANCE
ON BASE
CAMP
RIGHTS
RETIRED
PLAYERS
CARDS
SO
AN
AT
TIMES
MIGHT
REFER TO
BUT MY
IRL
IT
AS
AUTOGRAPH AGREEMENT
IN
INTERNALLY
THE
CATEGORY
THE
CARD CATEGORY WITH
AN
COMPETITORS
10 11 12 13
14
WITH
AGENT
WE
USE
WE USE
THE
WORD HIGHLIGHT
CALL
IT
AGREEMENT
ELSE
PLAYERS
WE CALL
IT
INC
MIGHT
SOMETHING
HIGHLIGHT
AGREEMENT
NOW SPECIFICALLY
IF
MY QUESTION PLAYER
TO
IS
YOU WANTED TO TO
AN
GET
VETERAN
DID
WHO WAS
15 16 17 18 19 20 21 22 23 24 25
ACTIVE
INTO
SIGN
CARDS
WITH
YOU HAVE
ENTER
AGREEMENT THERE
THEM ABOUT
THAT
MR EBERT
THE
THEM
PLAYER
BEING
WHO
ACTIVE
WE WOULD NEGOTIATE
THE
RESPECTIVE
AUTOGRAPH
AGREEMENT THROUGH PLAYERS
INC
AN
AGREEMENT WOULD BE
DRAWN UP BETWEEN TOPPS AND
THE
PLAYERS
RIGHTS
OF
INC
OR
FOR
SERVICES
OF
WHOEVER OR
APPEARANCE AND TELL
ME
OF
WHAT WAS
DLFFEIENT
80
ZUCKER ABOUT RETIRED
THAT
AS
HIGHLY
CONFIDENTIAL
THE SAME
OPPOSED TO
TO
AGREEMENT WITH
PLAYER
DO
THE
THING
IF
THE
AGREEMENT ITSELF WITH
YCU
WERENT FAMILIAR
AT
FOOTBALL
YOU THE
WOULD LOOK ONLY
IT
THEY WOULD LOOK SIMILAR
IS
DIFFERENCE WOULD BE
THE
RETIRED
AGREEMENT THERE
RIGHTS
PARAGRAPH
THATS
GRANTING
US
RIGHTS
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
THE
ACTIVE RIGHTS
PLAYER
AGREEMENT
WE ARE
WOULDNT
RECEIVING
HAVE THOSE
PARAGRAPH BECAUSE
RIGHTS
TO
RESPECTIVE THESE
MAKE CARDS
THROUGH ONE OF
LICENSING
AGREEMENTS
YOUVE PRESENTED
MR EBERT
REFERRINQ STICKER
TO
THE
WITNESS
IS
EXHIBITS
WHAT DOES
THAT
SAY
THE
WITNESS
390
IT
WOULD HE
394
393
DID
392
ANYONE FROM PLAYERS ALREADY HAD RIQHTS
INC
EVER
TELL
YOU
THAT
THEY
FROM CERTAIN
RETIRED
PLAYERS
NO
YOU
DIDNT
KNOW THAT
AT
AL
THE
MR EBERT
OBJECTION
109
CERTIFICATE
STATE
OF NEW YORK
SS
COUNTY OF NEW YORK
SOPHIE WITHIN
AND
NOLAN
STATE
NOTARY PUBLIC
OF NEW YORK DO
FOR THE
HEREBY CERTIFY
10 11 12 13 14 15 16 17 18 19 20
21
THAT
ADAM ZUCKER
IS
THE
WITNESS BEFORE SET
SUCH
WHOSE DEPOSITION
HEREIN
FORTH
WAS
DULY
IS
SWORN BY ME AND THAT
TRUE BY
DEPOSITION TESTIMONY
RECORD OF THE
GIVEN FURTHER
SUCH WITNESS
THAT AM NOT
TO
CERTIFY
OF
RELATED ACTION
AM THIS
IN
TO
ANY
THE
PARTIES
THIS THAT
BY
BLOOD OR MARRIAGE
IN
AND THE
NO WAY INTERESTED
OUTCOME OF
MATTER
IN
WITNESS
WHEREOF
14TH DAY
OF
HAVE
HEREUNTO
5TT
RN
HDND THIS
APILL
2008
22 23 24 25
F0
SOPHIE NOLAN
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