Parrish et al v. National Football League Players Incorporated

Filing 406

Declaration of ROY TAUB in Support of 405 MOTION in Limine DEFENDANTS MOTION IN LIMINE NO. 1 TO EXCLUDE EVIDENCE REGARDING HOW DEFENDANTS ALLEGEDLY SPENT MONIES CLAIMED BY PLAINTIFFS, AND EVIDENCE REGARDING THE ECONOMIC WEALTH OF DEFENDANTS AND ACTIVE NFL PLAYERS filed byNational Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Related document(s) 405 ) (Padnos, Todd) (Filed on 10/8/2008)

EXHIBIT 2

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

M.

Byrich

February

12

2008

191

all

over

again
MR. MR.

FEHER KATZ

Yes.

The
to

point now We
is

from we

which

we

were
is

starting part
of

the the and

direct

stipulate
we

not the

record.
Mr.

felt now

were
to

off

record

Feher

going

start his EXAMINATION
Q. 10

direct

examination. FEElER you
in

BY MR. Could note and

just look the

briefly at
statement period Do

Page
of

96042
NFLPA

financial
Inc.

11

the

Players
to

for the

12
13

from you

March
see

2005

February

28

2006.

note
A.
Q.

14

Yes.

15

Do

you

have paid

any
to

belief
Mr.

as

to as in

16

whether described way
to

any
in

amounts this

tlpshaw

17

note

can

be
in

traceable

any

18

licensing
MR. A.

revenues

particular
Leading.
to

19

KATZ

Objection. paid and one

20 21 22
23

The
in

compensation the

Mr.

Upshaw not

both

NFLPA
to

Players
revenue

Inc.

were

tied

directly

any

source.
Q.

24 25

So

do

you

have
in

belief any way
to

as

to

whether

its

traceable

licensing

PALJLSSON
800.300.1214 REPORTING
LITIGATION SERVICES
WWW.PAULSONREPORTTNG.COM

619.239.4111

Glenn

H.

Eyrich

February

12

2008

192

revenue

in

any
MR.

way
KATZ
whatever tell Objection. your Leading.

Q.

And just The
as

belief

is

if

you

could
A.

us
paid
to

compensation result certain
of

Mr.

IJpshaw

employment
of

contracts to be

that paid not
10 11
12

stipulate from the

amounts

money and

fund
to

of

Players
one revenue No

Inc.

NFLPA

traceable

any

source. questions. for

MR. MR.

FERER KATZ

further recross

Ill

moment. EXAMINATION
Q.

13

BY MR. The
of

KATZ
revenues
P1

14

licensing monies

come and

into

15

general
is

pool

for both

NFLPA

16

that

correct
A. It

17
18

goes

into

their

respective

bank

accounts correct.
Q.

19

And

thats

just

general

pool

of

20 21
22

money
A.
Q.

Operating And
Mr.

account
is

yes.

Upshaw

paid

out

of

that

23

general

account
A.

right
he would be paid out
of

24

believe accounts.

25

the

operating

800.300.1214 REPORTING
LITIGATION SERVICES
WWW.PAULSONREPQRTING.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