Parrish et al v. National Football League Players Incorporated

Filing 438

Declaration of IAN PAPENDICK in Support of 436 MOTION in Limine DEFENDANTS MOTION IN LIMINE NO. 7 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)(Related document(s) 436 ) (Padnos, Todd) (Filed on 10/8/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 438

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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 IAN PAPENDICK IN SUPPORT OF DEFENDANTS' MOTION IN LIMINE NO. 7

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Dewey & LeBoeuf LLP

Declaration of Ian Papendick In Support of Defendants' Motion in Limine No. 7

Civ. Action No. C07 0943 WHA

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

DECLARATION OF IAN PAPENDICK I, Ian Papendick, 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 my pro hac vice application was granted by the Court on August 6, 2008. I make this Declaration in support of Defendants' Motion in Limine No. 7. I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. Attached hereto as Exhibit 1 is an email from Bernard Parrish, dated November 7, 2006, bearing bates number CLASS003725. 3. Attached hereto as Exhibit 2 is a document that was produced by Plaintiffs in this case, bearing bates numbers CLASS003005-06. 4. Attached hereto as Exhibit 3 is a true and correct copy of an excerpt from the transcript of the deposition of Bernard Parrish, dated March 13, 2008. 5. Attached hereto as Exhibit 4 is a true and correct copy of the Supplemental Report of Daniel A. Rascher, dated August 27, 2008. 6. Attached hereto as Exhibit 5 is a true and correct copy of a letter from LaShun Lawson to Jeremy Strauser, dated May 31, 2001, bearing bates numbers PI131529-30. 7. Attached hereto as Exhibit 6 is a true and correct copy of Plaintiffs' Responses and Objections to Defendants' Fourth Set of Interrogatories, dated May 21, 2008. /// /// /// /// /// /// ///
Declaration of Ian Papendick In Support of Defendants' Motion in Limine No. 7 Civ. Action No. C07 0943 WHA

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Dewey & LeBoeuf LLP

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

8. Attached hereto as Exhibit 7 is a true and correct copy of Plaintiffs' Supplemental Responses and Objections to Defendants' Fourth Set of Interrogatories, dated June 3, 2008. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: September 25, 2008

____/s/_Ian L. Papendick______ Ian L. Papendick

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