Parrish et al v. National Football League Players Incorporated

Filing 463

OBJECTIONS to Defendants' Trial Exhibits by Bernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Hilbert, Ryan) (Filed on 10/8/2008)

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Parrish et al v. National Football League Players Incorporated Doc. 463 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S MANATT, PHELPS & PHILLIPS, LLP RONALD S. KATZ (Bar No. CA 085713) E-mail: rkatz@manatt.com RYAN S. HILBERT (California Bar No. 210549) E-mail: rhilbert@manatt.com NOEL S. COHEN (California Bar No. 219645) E-mail: ncohen@manatt.com 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: (650) 812-1300 Facsimile: (650) 213-0260 MCKOOL SMITH, P.C. LEWIS T. LECLAIR (Bar No. CA 077136) E-mail: lleclair@mckoolsmith.com JILL ADLER NAYLOR (Bar No. CA 150783) E-mail: jnaylor@mckoolsmith.com 300 Crescent Court Dallas, TX 75201 Telephone: (214) 978-4984 Facsimile: (214) 978-4044 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT CIVIL ACTION NO. C07 0943 WHA ANTHONY ADDERLEY, and WALTER ROBERTS III, on behalf of themselves and PLAINTIFFS' OBJECTIONS TO all others similarly situated, DEFENDANTS' TRIAL EXHIBITS Plaintiffs, NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, a Virginia corporation, and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC, a Virginia corporation, Defendants. 20202979.1 Dallas 258080v3 Dallas 266289v1 Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S PLAINTIFFS' OBJECTIONS TO DEFENDANTS' TRIAL EXHIBITS Plaintiffs expressly reserve the right to augment, or otherwise modify their objections to Defendants' exhibits based on circumstances as they may evolve prior to the commencement of trial, including but not limited to Motions in limine or any other pre-trial motions or objections. Per the parties' agreement, Plaintiffs further reserve their right to object to Defendants' exhibits under Fed. R. Evid. 402 and 403 and for lack of foundation. Ex. No. 151 Description 03/08/2006 Email from Wyman to Moore re FW: H. Adderley (Skall Deposition, Ex. 151) [No Bates] 00/00/0000 "About Us," from RPFPJ Website (Adderley Deposition, Ex. 160) [CLASS000331CLASS000332 Objections Hearsay: This exhibit contains statements of Defendants' employees. Those statements are hearsay that do not fall within an exception. 403: This exhibit referencing the Retired Professional Football Players for Justice includes references to class counsel and Bernie Parrish, and has no probative value. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. 402/403: The Retired Professional Football Players for Justice Articles of Corporation is not relevant to any issues in this lawsuit, and has no probative value. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. Response Court's Ruling 160 161 00/00/0000 RPFPJ Articles of Incorporation (Adderley Deposition, Ex. 161) [CLASS000317 CLASS000332] 20202979.1 Dallas 258080v3 Dallas 266289v1 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 162 Description 03/09/2007 Email from Adderley to HeroesofFootball re: Check Out Our Website ­ www.playersforju stice.org (Adderley Deposition, Ex. 162) [CLASS002722 CLASS002723] 06/09/2007 Email String between Adderley, Parrish, and HeroesofFootball re: Retired NFL Players, More from Profootballtalk.co m (Adderley Deposition, Ex. 164) [CLASS002847 CLASS002848] Objections Response Court's Ruling 164 Hearsay: Neither J. Turney nor Bernie Parrish is a class representative, and their statements are hearsay that do not fall within an exception. 403: This document contains inflammatory statements that should be excluded, considering the minimal probative value of this exhibit. 20202979.1 Dallas 258080v3 Dallas 266289v1 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 166 Description 00/00/0000 Communication from Parrish re RPFPJ (Adderley Deposition, Ex. 166) [CLASS002713 CLASS0002718] Objections This exhibit consists of multiple documents, which Plaintiffs will address separately: CLASS2713-2716: Hearsay: This document includes statements of Bernie Parrish. 403: This document includes inflammatory statements with no probative value, and should be excluded. CLASS2717: No objection. CLASS2718: Hearsay: This document includes statements of Bernie Parrish. 403: This document includes inflammatory statements with no probative value, and should be excluded. 403: This document includes references to claims that have been dismissed by the Court, including those brought by Bernie Parrish, which will confuse the jury. Plaintiffs will withdraw the objection if Defendants redact any references to claims that have been dismissed by the Court. Response Court's Ruling 169 11/15/2007 Third Amended Complaint (Adderley Deposition, Ex. 169) [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 176 Description 02/04/2008 Plaintiffs' Objections and Responses to Defendants' First Set of Interrogatories, with Parrish Verification (Adderley Deposition, Ex. 176) [No Bates] Objections 403: This exhibit contains numerous legal objections to the scope of content of the interrogatories, which could confuse the jury. Plaintiffs will withdraw this objection if those objections are redacted. Parrish Verification: As Parrish is no longer a party to this action, the inclusion of Bernie Parrish's verification could confuse the jury, and Plaintiffs object to that part of this exhibit under rule 403. Furthermore, Bernie Parrish's verification of these interrogatories is hearsay. Response Court's Ruling 177 179 02/13/2008 Verification of Adderley for Plaintiffs' Objections and Responses to First Set of Interrogatories (Adderley Deposition, Ex. 177) [No Bates] 02/23/2007 First Amended Complaint (Adderley Deposition, Ex. 179) [No Bates] 403: This document includes references to claims that have been dismissed by the Court, including those brought by Bernie Parrish, which will confuse the jury. Plaintiffs will withdraw the objection if Defendants redact any references to claims that have been dismissed by the Court. 20202979.1 Dallas 258080v3 Dallas 266289v1 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 180 Description 06/21/2007 Second Amended Complaint (Adderley Deposition, Ex. 180) [No Bates] Objections 403: This document includes references to claims that have been dismissed by the Court, including those brought by Bernie Parrish, which will confuse the jury. Plaintiffs will withdraw the objection if Defendants redact any references to claims that have been dismissed by the Court. 403: This exhibit contains numerous legal objections to the scope of content of the interrogatories, which could confuse the jury. Plaintiffs will withdraw this objection if those objections are redacted. 402/403: This exhibit is a press release about the lawsuit generally, and is not relevant to the merits of the class's claims. The press release references class counsel and Bernie Parrish, and has no probative value. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. Response Court's Ruling 181 307 02/04/2008 Plaintiffs' Responses to Defendants' First Set of Requests for Admission (Adderley Deposition, Ex. 181) [No Bates] 00/00/0000 RPFPJ Website: Press Releases (M. Parrish Deposition, Ex. 307) [JUSTICE000207 JUSTICE000209] 20202979.1 Dallas 258080v3 Dallas 266289v1 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 310 Description 03/22/2007 Email from Parrish re: Chance to Vote Against Gene Upshaw et al., Join Today (M. Parrish Deposition, Ex. 310) [JUSTICE000182 JUSTICE000185] Objections Hearsay: Bernie Parrish is not a class representative, and his statements are hearsay that do not fall within an exception. 402/403: This exhibit includes inflammatory statements about Defendants' employees (referencing "Gene Upshaw and his gang"), and should be excluded, especially in light of its lack of probative value to the merits of this case. 402/403: This exhibit is a membership form for the Retired Professional Players for Justice group, and is wholly irrelevant to the issues in this litigation. This exhibit includes inflammatory statements about Defendants' employees (referencing "Gene Upshaw and his gang"), and should be excluded, especially in light of its lack of probative value to the merits of this case. Response Court's Ruling 311 00/00/0000 RPFPJ Membership Form (M. Parrish Deposition, Ex. 311) [JUSTICE000064 ] 20202979.1 Dallas 258080v3 Dallas 266289v1 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 315 Description 02/14/2007 Letter from Mutch to Marquez re: Retired Professional Football Players For Justice, Inc. (M. Parrish Ex. 315) [JUSTICE000018 ] Objections Hearsay: Mr. Mutch is not a class representative, and his statements are hearsay. 402/403: The content of this letter is about the incorporation of The Retired Professional Football Players for Justice Articles, and is not relevant to any issues in this lawsuit. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. Authentication: The letter must be authenticated before Defendants can admit this into evidence. 402/403: The Retired Professional Football Players for Justice Articles of Corporation is not relevant to any issues in this lawsuit, and has no probative value. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. 403: There is minimal probative value in understanding the membership structure of the RPFPJ. This exhibit may confuse the jury, as it lists class counsel on its membership page. In light of its minimal probative value, the Court should exclude this exhibit under Rule 403. Response Court's Ruling 316 RPFPJ Articles of Incorporation (M. Parrish Deposition, Ex. 316) [No Bates] 321 00/00/0000 RPFPJ Website: Officers and Directors (M. Parrish Deposition, Ex. 321) [JUSTICE000218 JUSTICE000219] 20202979.1 Dallas 258080v3 Dallas 266289v1 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 350 Description 07/24/2006 Email from Parrish to Retired Players re: A Few Complaints That Have Been Sent to Government Agencies, State Attorney Generals, and Congressman (Parrish Deposition, Ex. 350) [No Bates] 07/17/2007 Email from Arnett to Parrish re: Lets Join Forces on Class Action Suit (Parrish Deposition, Ex. 351) [CLASS003220] Objections Hearsay: Mr. Parrish's statements are hearsay. 403: This exhibit includes inflammatory statements (referencing "actuarial bull shit," "goon squad," and "Gene Upshaw and his gang"), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Arnett is not a class representative, and his statements are hearsay. 403: This exhibit includes inflammatory statements (referencing "kick their asses," "puppet," and "they drink at the same trough"), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Parrish's statements are hearsay. 403: This exhibit includes inflammatory statements (referencing "man of color" and other racial statements), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Parrish's and Mr. Mutch's statements are hearsay. 402/403: Mr. Parrish's position regarding any lawsuits filed against him is irrelevant to any issues remaining in this lawsuit. Response Court's Ruling 351 352 08/14/2006 Email from Parrish to Retired Players re: Original Open Letter to Troy Vincent NFLPA Pres. (Parrish Deposition, Ex. 352) [No Bates] 353, 353A 10/9/2006 Letter from Mutch to Yablonski re: Addendum to Parrish Response to 8/29/2006 Letter (Parrish Deposition, Ex. 353, 353A) [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 354 Description 00/00/0000 NFLPA Understating Income ?? Prevaricating and Covering Tracks (Parrish Deposition, Ex. 354) [CLASS002703 CLASS002711] 08/2/2006 Email from Smith to Retired Players re: Here Is an Email I Sent to Andre Collins When I Started Back in 2006 (Parrish Deposition, Ex. 355) [No Bates] Objections Hearsay: Mr. Parrish's statements are hearsay. 403: This exhibit includes inflammatory statements (including professional attacks on Defendants' attorneys), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Pivec, Mr. Smith, and Mr. Parrish are not class representatives, and their statements are hearsay. 403: This exhibit includes inflammatory statements (including comparisons between Mr. Upshaw and Saddam Hussein, Milosevic, and Stalin), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Dobler and Mr. Parrish are not class representatives, and their statements are hearsay. 402/403: This exhibit references the filing of the lawsuit itself, and is irrelevant to the merits of the remaining claims. This exhibit includes inflammatory statements (including "Upshaw is dead meat" and calling Mr. Upshaw "garbage"), and should be excluded, especially in light of its lack of probative value to the merits of this case. Response Court's Ruling 355 356 02/20/2007 Email from Parrish to Dobler re: Be On Our Board Would (Parrish Deposition, Ex. 356) [CLASS003718 CLASS9003719] 20202979.1 Dallas 258080v3 Dallas 266289v1 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 357 Description 11/18/2007 Email from Charles Parrish to Parrish re: NFLPA RICO Racket? (Parrish Deposition, Ex. 357) [CLASS003053 CLASS003093] Objections Hearsay: Mr. Charles Parrish, Mr. Buoniconti, and Mr. Bernie Parrish are not class representatives, and their statements are hearsay. 402/403: This exhibit includes inflammatory statements (including calling Mr. Upshaw a "thuggish dictator"), and should be excluded, especially in light of its lack of probative value to the merits of this case. Hearsay: Mr. Charles Parrish and Mr. Bernie Parrish are not class representatives, and their statements are hearsay. Response Court's Ruling 358 10/13/2007 Email from Charles Parrish to Parrish re: NFLPA (Parrish Deposition, Ex. 358) [CLASS003172 CLASS003173] 359 402/403: This exhibit includes inflammatory statements (including references to Defendants' employees as "thugs" and references to brainwashing), and should be excluded, especially in light of its lack of probative value to the merits of this case. 09/18/2007 Article Third-party news article: Entitled "Victims This article contains of Self Neglect" statements that are hearsay. by Jason Cole (Parrish Deposition, Ex. 359) [[No Bates] The article must be authenticated before Defendants can admit this into evidence. 20202979.1 Dallas 258080v3 Dallas 266289v1 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 360 Description 10/28/2007 Email from Parrish to Retired Players re: The Retired Player Issue Are Not Going Away (Parrish Deposition, Exhibit 360) [No Bates] Objections Hearsay: Mr. Bernie Parrish is not a class representative, and his statements are hearsay. Response Court's Ruling 362 402/403: This exhibit includes inflammatory statements (including threats of potential lawsuits, and a characterization of Mr. Upshaw as a "biblethumping money grubbing hypocrite"), and should be excluded, especially in light of its lack of probative value to the merits of this case. 11/07/2007 Email Hearsay: Mr. Parrish's from Lynch to and Mr. Lynch's Parrish re: Parrish statements are hearsay. Documents (Parrish Deposition, Ex. 362) [CLASS003160] 363 12/15/2007 Email from Lynch to Parrish re: Does This Come Through As One Document Or Does The Audit Overlay It (Parrish Deposition, Ex. 363) [CLASS003152 CLASS003158] 402/403: This exhibit references documents filed in this lawsuit, and does not include admissible evidence relating to the merits of the remaining claims. Hearsay: Mr. Parrish's and Mr. Lynch's statements are hearsay. 402/403: This exhibit includes inflammatory statements (including a characterization of Mr. Upshaw as a "control freak," and characterizing those that work for him as "scurry[ing] around" and "licking [him],"), and should be excluded, especially in light of its lack of probative value to the merits of this case. 20202979.1 Dallas 258080v3 Dallas 266289v1 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 366 Description 11/20/2006 Email from Pyle to Retired Players re: Bernie Parrish Stuff (Parrish Deposition, Ex. 366) [No Bates] Objections Hearsay: Mr. Parrish's, Mr. Pyle's, and Mr. Stabler's statements are hearsay. 402/403: This exhibit references documents gathered for this lawsuit, and does not include admissible evidence relating to the merits of the remaining claims. Hearsay: Mr. Parrish's and Mr. Dobler's statements are hearsay. 402/403: This exhibit references addresses a potential unrelated lawsuit, and also includes inflammatory racial comments in relation to Mr. Uphsaw, and does not include admissible evidence relating to the merits of the remaining claims. In light of its lack of probative value, the Court should exclude this exhibit. Hearsay: Mr. Parrish's statements are hearsay. 402/403: This exhibit includes inflammatory statements (including a characterization of an employee as a "leashed pet," and various racial statements), and should be excluded, especially in light of its lack of probative value to the merits of this case. Response Court's Ruling 369 01/24/2007 Email from Parrish to Dobler re: Great Job (Parrish Deposition, Ex. 369) [CLASS004139 CLASS004169] 370 01/29/2007 Email from Parrish to Toner re: I Believe Item #9 Is a Criminal Offense That Occurred in the Hockey Union's Case Against Eagelson (Parrish Deposition, Ex. 370) [CLASS004220 CLASS004250] 20202979.1 Dallas 258080v3 Dallas 266289v1 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 371 Description 02/14/2007 Complaint (Parrish Deposition, Ex. 371) [No Bates] Objections 403: This exhibit includes references to claims that have been dismissed by the Court, including those brought by Bernie Parrish, which will confuse the jury. Plaintiffs will withdraw the objection if Defendants redact any references to claims that have been dismissed by the Court. Hearsay: Mr. Parrish's statements are hearsay. 402/403: This exhibit is an excerpt from Mr. Parrish's book They Call it a Game. This book has no probative value to the merits of the remaining claims in this lawsuit, and should be excluded. Hearsay: Mr. Parrish's statements are hearsay. Response Court's Ruling 373 00/00/0000 Photocopy of They Call It A Game (Parrish Deposition, Ex. 373) [No Bates] 374 375 402: This exhibit purports to show Mr. Parrish's proposed platform for a potential candidacy for Executive Director of the NFLPA. This platform has no probative value to the remaining claims in this lawsuit, and should be excluded. Email from Hearsay: Mr. Parrish's Rhoden to Parrish and Mr. Bill Roden's re: Bernie Call Me statements are hearsay. ... IMP! (Parrish Deposition, Ex. 375) [CLASS003133] 00/00/0000 Note Stating Parrish Will Run for Executive Director (Parrish Deposition, Ex. 374) [CLASS003426] 402/403: This exhibit addresses issues collateral to this lawsuit, and has no probative value to the merits of the remaining claims in this lawsuit, and should thus be excluded. 20202979.1 Dallas 258080v3 Dallas 266289v1 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 376 Description 11/28/2007 Email from DeLamielleure to Parrish re: Approval of Bylaws of RPFPJ (Parrish Deposition, Ex. 376) [CLASS003164 CLASS003165] Objections Hearsay: Mr. Parrish's and Mr. Joe Delamielleure's statements are hearsay. 402/403: This exhibit addresses the bylaws of the Retired Professional Football Players for Justice, which is an issue that is collateral to this lawsuit. This exhibit has no probative value to the merits of the remaining claims in this lawsuit, and would result in a waste of time, and should be excluded. Hearsay: Mr. Parrish's and Mr. Lynch's statements are hearsay. 402/403: This exhibit purports to show Mr. Parrish's proposed platform for a potential candidacy for Executive Director of the NFLPA. This platform has no probative value to the remaining claims in this lawsuit, and should be excluded. Hearsay: Mr. Parrish's and Mr. Oben's statements are hearsay. 402/403: This exhibit contains Mr. Oben's opinion that Mr. Parrish would not be an effective leader for the NFLPA, and includes personal attacks on Mr. Parrish. This exhibit has no probative value to the remaining claims in this lawsuit, and should be excluded. Response Court's Ruling 377 11/24/2007Email from Lynch to Parrish re: What Do You Think? (Parrish Deposition, Ex. 377) [CLASS003161] 378 12/9/2007 Email from Romano to Parrish re: Endorsement by NYTmes Bill Rhoden (Parrish Deposition, Ex. 378) [CLASS003103 CLASS003106] 20202979.1 Dallas 258080v3 Dallas 266289v1 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 379 Description 00/00/0000 Dave Pear's Official Blog: Parrish Entry (Parrish Deposition, Ex. 379) [No Bates] 02/14/2007 Letter from Mutch to Marquez re: Retired Professional Football Players For Justice, Inc. (Parrish Deposition, Ex. 380, M. Parrish Deposition, Ex. 315) [CLASS000330] Objections Hearsay: Mr. Parrish's and Mr. Pear's statements are hearsay. Response Court's Ruling 380 Hearsay: Mr. Mutch is not a class representative, and his statements are hearsay. 402/403: The content of this letter is about the incorporation of The Retired Professional Football Players for Justice, and is not relevant to any issues in this lawsuit. Referencing this exhibit would be a waste of time, and may require Plaintiffs to present argument on collateral issues to rebut any inferences raised by this exhibit. Authentication: The letter must be authenticated before Defendants can admit it into evidence. 20202979.1 Dallas 258080v3 Dallas 266289v1 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 382 Description 02/06/2007 Parrish Blog Entry Entitled "Bizarre Gene Upshaw Email" (Parrish Deposition, Ex. 382) [No Bates] Objections Hearsay: Mr. Parrish's statements are hearsay. 403: This exhibit is a 130page printout of what appears to be excerpts from Bernie Parrish's weblog, "Parrish the Thought." Numerous statements found in this weblog do not relate to the issues in this lawsuit whatsoever. Introduction of a document of this length, peppered with irrelevant information, is a waste of time, and should be excluded under rule 403. Additionally, many statements found within this weblog are inflammatory, and should be excluded in light of their minimal probative value. Hearsay: Mr. Parrish's statements are hearsay. 403: This exhibit is a 24page printout of what appears to be excerpts from Bernie Parrish's weblog, "Parrish the Thought." Numerous statements found in this weblog do not relate to the issues in this lawsuit whatsoever. Additionally, many statements found within this exhibit are inflammatory, and should be excluded in light of their minimal probative value. Response Court's Ruling 383 01/09/2008 Parrish the Thought Blog Entry (Parrish Deposition, Ex. 383) [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 388 Description 03/01/2008 Email from Henderson to Upshaw re: The Pellman-AonGoodell Alliance (Parrish Deposition, Ex. 388) [No Bates] Objections Hearsay: Mr. Parrish's statements are hearsay. Response Court's Ruling 418 403: This exhibit includes inflammatory statements (including a characterization of Mr. Upshaw as a "leashed pet," and characterizing Mr. Parrish as a "madman"), and should be excluded, especially in light of its lack of probative value to the merits of this case. 00/00/0000 Letter Authentication: This from Goodstadt to letter must be authenticated Haza (Friss before Defendants can use Deposition, Ex. it as evidence. 418) [PI108056 PI108060] 622 624 2000 2001 06/13/2008 Expert Report of G. Steven Jizmagian (Jizmagian Deposition, Ex. 622) [No Bates] 06/12/2008 Expert Report of Roger G. Noll (Noll Deposition, Ex. 624) [No Bates] 8/29/2007 STATS LLC License Agreement, Effective 03/01/2007 [PI101842 PI101856] 03/24/2005 Upper Deck - Ottis Anderson Ad Hoc [PI016913 PI016914] Hearsay: If this draft letter was never sent to Topps, it would be used for the truth of the matters listed therein, and would constitute hearsay. Hearsay: This is the expert report of Defendants' retained expert, Mr. Jizmagian. This report is hearsay. Hearsay: This is the expert report of Defendants' retained expert, Mr. Noll. This report is hearsay. 20202979.1 Dallas 258080v3 Dallas 266289v1 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2002 Description 03/30/2005 Upper Deck - Tony Dorsett Ad Hoc [PI017012 PI017013] 03/24/2005 Upper Deck - Chuck Foreman Ad Hoc [PI017040 PI017041] 03/14/2005 Upper Deck - Harold Jackson Ad Hoc [PI017109 PI017110] 03/31/2005 Upper Deck - Don Maynard Ad Hoc [PI017194] 03/14/2005 Upper Deck - Mark Van Eeghan Ad Hoc [PI017316 PI017317] 03/20/2005 Upper Deck - Troy Aikman Ad Hoc [PI016900 PI016901] 03/10/2005 Upper Deck - Marcus Allen Ad Hoc [PI016906 PI016907] 03/31/2005 Upper Deck - Joe Montana Ad Hoc [PI017203 PI017204] 03/24/2005 Upper Deck - Raymond Berry Ad Hoc [PI016929 PI016930] 03/24/2005 Upper Deck - Len Dawson Ad Hoc [PI016981 PI016982] Objections Response Court's Ruling 2003 2004 2005 2006 2007 2008 2009 2010 2011 20202979.1 Dallas 258080v3 Dallas 266289v1 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2012 Description 03/31/2005 Upper Deck - Cris Collinsworth Ad Hoc [PI016971 PI016972] 03/31/2005 Upper Deck - Dan Fouts Ad Hoc [PI017047 PI017048] 03/11/2005 Upper Deck - Russ Francis Ad Hoc [PI017050 PI017051] 03/11/2005 Upper Deck - L.C. Greenwood Ad Hoc [PI017062 PI017063] 03/14/2005 Upper Deck - Jack Ham Ad Hoc [PI017073 PI017074] 03/14/2005 Upper Deck - Franco Harris Ad Hoc [PI017082 PI017083] 03/22/2005 Upper Deck - Paul Hornung Ad Hoc [PI017094 PI017095] 03/31/2005 Upper Deck - Bo Jackson Ad Hoc [PI017104 PI017105] 03/30/2005 Upper Deck - Deacon Jones Ad Hoc [PI017120] 03/17/2005 Upper Deck - Steve Largent Ad Hoc [PI017152 PI017153] Objections Response Court's Ruling 2013 2014 2015 2016 2017 2018 2019 2020 2021 20202979.1 Dallas 258080v3 Dallas 266289v1 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2022 Description 03/30/2005 Upper Deck - James Lofton Ad Hoc [PI017162 PI017163] 03/31/2005 Upper Deck - Jim Marshall Ad Hoc [PI017183] 03/14/2005 Upper Deck - Joe Theismann Ad Hoc [PI017287 PI017288] 03/14/2005 Upper Deck - Lenny Moore Ad Hoc [PI017205 PI017206] 03/14/2005 Upper Deck - Ozzie Newsome Ad Hoc [PI017215 PI017216] 03/31/2005 Upper Deck - Jim Plunkett Ad Hoc [PI017235 PI017236] 03/22/2005 Upper Deck - Merlin Olson Ad Hoc [PI017219 PI017220] 03/14/2005 Upper Deck - Charley Taylor Ad Hoc [PI017277 PI017278] 05/24/2006 Financial Records Regarding HOF Deal [PI051532 PI051542] 05/28/2004 EA Joe Green Ad Hoc [PI009619] 06/15/2004 EA Cris Carter Ad Hoc [PI067232] Objections Response Court's Ruling 2023 2024 2025 2026 2027 2028 2029 2030 Authentication: This exhibit must be authenticated before Defendants can admit it into evidence. 2031 2032 20202979.1 Dallas 258080v3 Dallas 266289v1 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2033 Description 07/27/2004 EA Eric Dickerson Ad Hoc [PI067235] 09/28/2004 EA Darrell Green Ad Hoc [PI067250] 07/28/2004 EA Bo Jackson Ad Hoc [PI067241] 05/28/2004 EA Anthony Munoz Ad Hoc [PI067223] 05/28/2004 EA Mike Singletary Ad Hoc [PI009632] 06/01/2004 EA Jack Lambert Ad Hoc [PI067229] 08/03/2004 EA Sterling Sharpe Ad [PI067244] 07/28/2004 EA Joey Browner Ad Hoc [PI067238] 07/28/2004 EA Bo Jackson Ad Hoc [EA000003 EA000004] 07/27/2004 EA Eric Dickerson Ad Hoc [EA000009 EA0000010] 07/28/2004 EA Joey Browner Ad Hoc [EA000013 EA000014] 08/03/2004 EA Sterling Sharpe Ad Hoc [EA000021 EA000022] 05/28/2004 EA Randall Cunningham Ad Hoc [PI067217] 06/00/2004 June 2004 Touchback [PI140852 PI140855] Objections Response Court's Ruling 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 Hearsay: Defendants' statements as made in this Touchback newsletter are hearsay. 20202979.1 Dallas 258080v3 Dallas 266289v1 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2047 Description 00/00/0000 Attachment A to EA License Agreement Active Player GLA Form [PI000070] 04/01/2003 Racing Champions ERTL Corp. License Agreement, Effective 03/01/2001 [PI006374 PI006385] 06/13/2008 Table I to the Report of G. Stephen Jizmagian: Comparison of Retired Player Licensing Revenue and Active Player Shared Pool Revenue [No Bates] Objections Authentication: The agreement must be authenticated before Defendants can admit it into evidence. Response Court's Ruling 2048 2049 Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Jizmagian. Any analysis from this report is hearsay. 403: improperly juxtaposes retired players licensing payments with active player licensing payments, which could mislead the jury, and should be excluded. 20202979.1 Dallas 258080v3 Dallas 266289v1 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2050 Description 06/13/2008 Table II to the Report of G. Stephen Jizmagian: Comparison of Actual Pool [No Bates] Objections Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Jizmagian. Any analysis from this report is hearsay. 403: this exhibits focuses on active player payments, which is not materially probative to the merits of Plaintiffs' remaining claims, and should be excluded. Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Noll. Any analysis from this report is hearsay. Improper Rule 1006 Summary: this exhibit does not list the documents relied on to create this summary; thus, the underlying documents have not been "made available" under Rule 1006. As a result, this exhibit should be excluded under Rule 1006. Response Court's Ruling 2051 06/12/2008 Table 1 to the Expert Report of Roger G. Noll: Distribution of Licensing Revenues among Members of the GLA Class, 2003 - early 2008 [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2052 Description 06/12/2008 Table 2 to the Expert Report of Roger G. Noll: Distribution of Licensing Revenues among Members of the GLA Class [No Bates] Objections Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Noll. Any analysis from this report is hearsay. Improper Rule 1006 Summary: this exhibit does not list the documents relied on to create this summary; thus, the underlying documents have not been "made available" under Rule 1006. As a result, this exhibit should be excluded under Rule 1006. Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Noll. Any analysis from this report is hearsay. Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Noll. Any analysis from this report is hearsay. Response Court's Ruling 2053 2054 06/12/2008 Table 3 to the Expert Report of Roger G. Noll: Estimates of Licensing Revenues, Disbursements to Players and Share of Gross Revenues Paid to Players [No Bates] 06/12/2008 Table 4 to the Expert Report of Roger G. Noll: Percentage of Licensing Income Paid to Players [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2055 Description 00/00/0000 Escrow Agreement Form from Sun Trust Bank [No Bates] 00/00/0000 Federal Rule of Evidence 1006 Compilation: Class Members' Royalties (From PI051545PI051550, PI135609PI139710, PI139723PI140368) [No Bates] Objections Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This compilation must be authenticated before Defendants can admit this into evidence. Hearsay: Defendants' statements regarding fees paid to various players are hearsay, and should be excluded. 403: this document appears to be a summary of "video game fees" paid to certain players. Evidence of payments pursuant to other agreements may confuse the jury as to whether the class members have been properly paid under the GLA, and has minimal probative value to the merits of the remaining claims, and should be excluded. Authentication: This compilation must be authenticated before Defendants can admit this into evidence. Demonstrative: Plaintiffs object to this exhibit because it is demonstrative evidence that should not be admitted into evidence. Hearsay: This is a portion the expert report of Defendants' retained expert, Mr. Noll. Any analysis from this report is hearsay. Response Court's Ruling 2056 2057 2059 Various Dates Federal Rule of Evidence 1006 Compilation: Class Members' GLAs [No Bates] 00/00/0000 Royalty and Credited Seasons Data.xls prepared for the Expert Report of Roger G. Noll [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2060 Description 06/29/2007 AOL LLC License Agreement, Effective 03/01/2007 [PI101946 PI101961] 00/00/0000 CBS Interactive Inc. License Agreement, Effective 03/01/2007 [PI101670 PI101680] 01/20/2000 EA License Agreement, Effective 03/01/1998 [PI132982 PI132992] 08/08/2006 EA License Agreement, Effective 03/01/2006 [PI000042 PI000054] 01/12/2006 EA License Agreement, Effective 03/01/2006 [PI000022 PI000041] 00/00/0000 Epic Cycle License Agreement, Effective 03/01/2004 [PI104550 PI104561] 09/06/2007 Fathead License Agreement, Effective 03/01/2007 [PI101962 PI101975] Objections Response Court's Ruling 2061 2062 2063 2064 2065 2066 20202979.1 Dallas 258080v3 Dallas 266289v1 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2067 Description 08/07/2007 Fox Sports Interactive Media License Agreement, Effective 03/01/2007 [PI101897 PI101920] 07/07/2004 Game Time LLC License Agreement, Effective 03/01/2004 [PI008034 PI008046] 00/00/0000 GSI License Agreement, Effective 03/01/2006 [PI126542 PI126554] 09/30/2007 Head2Head Sports License Agreement, Effective 3/1/2007 [PI101870 PI101883] 00/00/0000 Joy Athletic License Agreement, Effective 03/01/2003 [PI105182 PI105194] 12/19/2006 MBI Incorporated License Agreement Effective 03/01/2007 [PI101829 PI101841] 00/00/0000 MJM Sports License Agreement, Effective 03/01/2004 [PI099443 PI099455] Objections Response Court's Ruling 2068 2069 2070 2071 2072 2073 20202979.1 Dallas 258080v3 Dallas 266289v1 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2074 Description 00/00/0000 MJM Sports License Agreement, Effective 03/01/2006 [PI111645 PI111657] 07/31/2007 MVP Galleries License Agreement, Effective 03/01/2007 [PI101816 PI101828] 00/00/0000 NBC Sports License Agreement, Effective 03/01/2007 [PI101857 PI101869] 00/00/0000 No Huddle License Agreement, Effective 03/01/2004 [PI117826 PI117839] 11/03/2004 Onfield Apparel License Agreement, Effective 03/01/2001 [PI006429 PI006532] 10/08/2004 Riddell, Inc. License Agreement, Effective 03/01/2004 [PI126283 PI126296] 00/00/0000 Screenlife LLC License Agreement, Effective 03/01/2005 [PI099742 PI099754] Objections Response Court's Ruling 2075 2076 2077 2078 2079 2080 20202979.1 Dallas 258080v3 Dallas 266289v1 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2081 Description 07/27/2004 Stahls' Special Projects, Inc. License Agreement, Effective 03/01/2004 [PI006758 PI006769] 10/16/2007 Upper Deck License Agreement, Effective 03/01/2007 [PI134286 PI134300] 11/30/2007 VF Imagewear License Agreement, Effective 03/01/2007 [PI134987 PI135000] 03/18/2007 Topps Service Agreement, Effective 03/01/2007 [PI007383 PI007396] 10/16/2007 Upper Deck Service Agreement, Effective 03/01/2007 [PI101787 PI101802] 03/10/2005 Upper Deck - Adderley Ad Hoc [PI088509 PI088511] 07/08/2005 Upper Deck - Adderley Ad Hoc [P1087805] 07/08/2005 Upper Deck - Adderley Ad Hoc [PI087803 PI087804] Objections Response Court's Ruling 2082 2083 2084 2085 2086 2087 2088 20202979.1 Dallas 258080v3 Dallas 266289v1 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2089 Description 08/15/2005 Upper Deck - Adderley Ad Hoc [PI088054 PI088055] 08/15/2005 Upper Deck - Adderley Ad Hoc [PI088052 PI088053] 08/15/2005 Upper Deck - Vernand Morency Ad Hoc [PI087974 PI087975] 08/15/2005 Upper Deck - Vernand Morency Ad Hoc [PI087976] 04/08/2003 Letter Agreement between Adderley and PI re: Reebok Deal [CLASS001746] 06/14/2004 EA Joe Greene Ad Hoc [PI067218 PI067219] 06/14/2004 EA Randall Cunningham Ad Hoc [PI067215 PI067216] 01/28/2007 EA Willis McGahee Ad Hoc [PI053615 PI053617] 08/03/2007 TMP Jack Lambert Ad Hoc [PI032952] 08/06/2007 TMP Jack Lambert Ad Hoc [PI032971 PI032972] 08/01/2007 TMP Howie Long Ad Hoc [PI032957] Objections Response Court's Ruling 2090 2091 2092 2093 2094 2095 2096 2097 2098 2099 20202979.1 Dallas 258080v3 Dallas 266289v1 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2100 Description 08/01/2007 TMP Howie Long Ad Hoc [PI032974 PI032975] 08/03/2007 TMP Warren Moon Ad Hoc [PI032959] 08/06/2007 TMP Warren Moon Ad Hoc [PI032977 PI032978] 08/03/2007 TMP John Riggins Ad Hoc [PI032962] 08/06/2007 TMP John Riggins Ad Hoc [PI032980 PI032981] 08/09/2007 TMP Fran Tarkenton Ad Hoc [PI032965] 08/09/2007 TMP Fran Tarkenton Ad Hoc [PI032953] 08/09/2007 TMP Frank Tarkenton Ad Hoc [PI032983 PI032984] 08/03/2007 TMP Steve Young Ad Hoc [PI032967] 08/06/2007 TMP Steve Young Ad Hoc [PI032986 PI032987] 07/06/2006 TMP Roger Staubach Ad Hoc [PI014531] 07/06/2006 TMP Bo Jackson Ad Hoc [PI014517] 00/00/0000 TMP Ronnie Lott Ad Hoc [PI014519] 07/06/2006 TMP Dan Marino Ad Hoc [PI014521] Objections Response Court's Ruling 2101 2102 2103 2104 2105 2106 2107 2108 2109 2110 2111 2112 2113 20202979.1 Dallas 258080v3 Dallas 266289v1 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2114 Description 00/00/0000 TMP Joe Montana Ad Hoc [PI014523] 00/00/0000 TMP Walter Payton Ad Hoc [PI014525] 07/06/2006 TMP Earl Campbell Ad Hoc [PI054235 PI054236] 07/06/2006 TMP John Elway Ad Hoc [PI014515] 07/06/2006 TMP Reggie White Ad Hoc [PI014529] 08/02/2004 TMP Jim Brown Ad Hoc [PI018659] 05/27/2004 TMP Johnny Unitas Ad Hoc [PI018743] 05/27/2004 TMP Lawrence Taylor Ad Hoc [PI018762] 05/27/2004 TMP Barry Sanders Ad Hoc [PI018760] 05/27/2004 TMP Joe Greene Ad Hoc [PI018750] 05/27/2004 TMP Franco Harris Ad Hoc [PI018752] 11/09/2004 Topps - Roger Craig Ad Hoc [PI021560 PI021561] 03/16/2006 Topps - Troy Aikman Ad Hoc [PI054053 PI054054] 04/03/2006 Topps - Sammy Baugh Ad Hoc [PI054058 PI054059] Objections Response Court's Ruling 2115 2116 2117 2118 2119 2120 2121 2122 2123 2124 2125 2126 2127 20202979.1 Dallas 258080v3 Dallas 266289v1 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2128 Description 09/18/2006 Topps - Chuck Bednarik Ad Hoc [PI054063 PI054064] 01/09/2007 Topps - Fred Biletnikoff Ad Hoc [PI054069 PI054070] 07/05/2006 Topps - Terry Bradshaw Ad Hoc [PI054074 PI054075] 01/07/2007 Topps - Jim Brown Ad Hoc [PI054079 PI054080] 04/03/2006 Topps - Earl Campbell Ad Hoc [PI054088 PI054089] 09/26/2006 Topps - Eric Dickerson Ad Hoc [PI054097 PI054098] 08/17/2006 Topps - Art Donovan Ad Hoc [PI054104 PI054105] 01/04/2007 Topps - Tony Dorsett Ad Hoc [PI054109 PI054110] 12/11/2006 Topps - John Elway Ad Hoc [PI054111 PI054112] 12/05/2006 Topps - Frank Gifford Ad Hoc [PI054118 PI054119] 10/23/2006 Topps - Paul Hornung Ad Hoc [PI054122 PI054123] Objections Response Court's Ruling 2129 2130 2131 2132 2133 2134 2135 2136 2137 2138 20202979.1 Dallas 258080v3 Dallas 266289v1 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2139 Description 05/08/2006 Topps - Bo Jackson Ad Hoc [PI054132 PI054133] 06/20/2006 Topps - Jim Kelly Ad Hoc [PI054137 PI054138] 08/10/2006 Topps - Gino Marchetti Ad Hoc [PI054142 PI054143] 01/04/2007 Topps - Dan Marino Ad Hoc [PI054148 PI054149] 10/24/2006 Topps - Joe Theismann Ad Hoc [PI054210 PI054211] 07/05/2006 Topps - Joe Montana Ad Hoc [PI054160 PI054161] 04/03/2006 Topps - Bronko Nagurski Ad Hoc [PI054165 PI054166] 08/01/2006 Topps - Joe Namath Ad Hoc [PI054167 PI054168] 07/11/2006 Topps - Emmitt Smith Ad Hoc [PI054208 PI054209] 04/26/2006 Topps - Walter Payton Ad Hoc [PI054179 PI054180] 10/24/2006 Topps - Jim Plunkett Ad Hoc [PI054181 PI054182] 12/11/2006 Topps - Jerry Rice Ad Hoc [PI054192 PI054193] Objections Response Court's Ruling 2140 2141 2142 2143 2144 2145 2146 2147 2148 2149 2150 20202979.1 Dallas 258080v3 Dallas 266289v1 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2151 Description 11/29/2006 Topps - Barry Sanders Ad Hoc [PI054199 PI054200] 08/30/2006 Topps - Plaxico Burress Ad Hoc [PI053933 PI053934] 10/20/2005 Fathead - Jack Lambert Ad Hoc [PI055108] 11/08/2005 Fathead - Boomer Esiason Ad Hoc [PI055109] 10/26/2005 Fathead - Marcus Allen Ad Hoc [PI055110] 10/20/2005 Fathead - Barry Sanders Ad Hoc [PI055111] 10/26/2005 Fathead - Emmitt Smith Ad Hoc [PI055112] 10/26/2005 Fathead - John Elway Ad Hoc [PI055113] 11/22/2005 Fathead Lawrence Taylor Ad Hoc [PI055114] 11/08/2005 Fathead - Dan Marino Ad Hoc [PI055116] 11/07/2005 Fathead - Jerry Rice Ad Hoc [PI055117] 11/07/2005 Fathead - Troy Aikman Ad Hoc [PI055118] Objections Response Court's Ruling 2152 2153 2154 2155 2156 2157 2158 2159 2160 2161 2162 20202979.1 Dallas 258080v3 Dallas 266289v1 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2163 Description 12/12/2005 Fathead - Walter Payton Ad Hoc [PI055121] 11/08/2005 Fathead - Bernie Kosar Ad Hoc [PI055122] 12/21/2005 Fathead - Joe Montana Ad Hoc [PI055123] 01/10/2006 Fathead Shannon Sharpe Ad Hoc [PI055124] 05/10/2005 Fathead - Ben Roethlisberger Ad Hoc [PI055128 PI055130] 05/04/2004 USAopoly - Dan Marino Ad Hoc [PI020982] 05/04/2004 USAopoly - Dan Marino Ad Hoc [PI056601 PI056602] 05/27/2004 TMP Ray Nitschke Ad Hoc [PI018754] 08/16/2005 Motorola - Willie Lanier Ad Hoc [PI016593] 07/31/2007 Playoff Corporation Willie Lanier Ad Hoc [PI031947 PI031948] 09/21/2006 Sprint - Willie Lanier Ad Hoc [PI062205 PI062207] Objections Response Court's Ruling 2164 2165 2166 2167 2168 2169 2170 2171 2172 2173 20202979.1 Dallas 258080v3 Dallas 266289v1 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2174 Description 09/09/2005 Motorola - Willie Lanier Ad Hoc [PI070613 PI070615] 09/09/2005 Motorola - Willie Lanier Ad Hoc [PI070616] 09/21/2006 Sprint - Willie Lanier Ad Hoc [PI071275 PI071277] 07/31/2007 Playoff Corporation Willie Lanier Ad Hoc [PI080481 PI080482] 09/21/2006 Sprint - Willie Lanier Ad Hoc [PI062068 PI062070] 09/21/2006 Sprint - Willie Lanier Marketing Memo [PI004694] 07/25/2007 Gallo - Willie Lanier Marketing Memo [PI031088] 08/25/2003 NFL Willie Lanier Marketing Form and Terms of Agreement [PI048342] 07/20/2006 Gallo - Willie Lanier Marketing Memo [PI060586] 07/25/2007 Gallo - Willie Lanier Marketing Memo [PI063973] 10/21/2002 Oscar Mayer - Willie Lanier Marketing Form [PI064146] Objections Response Court's Ruling 2175 2176 2177 2178 2179 2180 2181 2182 2183 2184 20202979.1 Dallas 258080v3 Dallas 266289v1 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2185 Description 09/01/2003 NFL Willie Lanier Marketing Form [PI068246] 09/21/2006 Sprint - Willie Lanier Marketing Memo [PI071278] 06/20/2006 Press Pass - Tim Brown Ad Hoc [PI005179 PI005180] 04/20/2007 Playoff Corporation - Tim Brown Ad Hoc [PI013029] 04/30/2007 Topps - Tim Brown Ad Hoc [PI013290] 09/20/2005 EA Tim Brown Marketing Memo [PI013416] 08/29/2005 NFL Tim Brown Marketing Memo [PI013528] 08/30/2005 NFL Tim Brown Marketing Memo [PI013529] 09/21/2004 ESPN - Tim Brown Marketing Memo [PI021883] 04/20/2007 Playoff Corporation - Tim Brown Ad Hoc [PI031560 PI031561] 04/30/2007 Topps - Tim Brown Ad Hoc [PI033007 PI033008] 09/23/2003 Upper Deck - Tim Brown Ad Hoc [PI044246 PI044247] Objections Response Court's Ruling 2186 2187 2188 2189 2190 2191 2192 2193 2194 2195 2196 20202979.1 Dallas 258080v3 Dallas 266289v1 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2197 Description 09/23/2003 Playoff Corporation - Tim Brown Ad Hoc [PI049393 PI049394] 03/11/2003 Playoff Corporation - Tim Brown Ad Hoc [PI049866 PI049867] 06/20/2006 RC2 Brands - Tim Brown Ad Hoc [PI052930 PI052931] 01/05/2007 Topps - Tim Brown Ad Hoc [PI054043 PI054044] 01/05/2007 Topps - Tim Brown Ad Hoc [PI054086 PI054087] 12/18/2006 Reebok - Tim Brown Ad Hoc [PI055364 PI055366] 10/25/2004 Upper Deck - Tim Brown Ad Hoc [PI055542 PI055543] 09/21/2004 ESPN - Tim Brown Marketing Memo [PI065944] 09/20/2005 EA Tim Brown Marketing Memo [PI066756] 08/30/2005 NFL Tim Brown Marketing Memo [PI068364] 08/29/2005 NFL Tim Brown Marketing Memo [PI068396] Objections Response Court's Ruling 2198 2199 2200 2201 2202 2203 2204 2205 2206 2207 20202979.1 Dallas 258080v3 Dallas 266289v1 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2208 Description 00/00/0000 Visa Tim Brown Marketing Form [PI068843] 00/00/0000 Visa Tim Brown Marketing Form [PI068844] 04/17/2007 NFL Tim Brown Marketing Memo [PI071354] 02/08/2007 NFL Tim Brown Marketing Memo [PI071765] 01/24/2006 News America - Tim Brown Ad Hoc [PI073726 PI073728] 01/24/2006 News America - Tim Brown Marketing Memo [PI073729] 04/20/2007 Playoff Corporation - Tim Brown Ad Hoc [PI080382 PI080383] 04/20/2007 Playoff Corporation - Tim Brown Ad Hoc [PI080384] 06/22/2007 Topps - Tim Brown Ad Hoc [PI084072 PI084073] 04/27/2007 Topps - Tim Brown Ad Hoc [PI084074] 01/05/2007 Topps - Tim Brown Ad Hoc [PI083997 PI083998] Objections Response Court's Ruling 2209 2210 2211 2212 2213 2214 2215 2216 2217 2218 20202979.1 Dallas 258080v3 Dallas 266289v1 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2219 Description 00/00/0000 GMC - Walter Payton, Lynn Swann, Otis Taylor Ad Hocs [PI004446 PI004451] 10/04/2003 Mike McBath GLA [PI028917] 11/17/2004 Andre Collins GLA [PI027801] 12/19/2002 Willie Lanier GLA [PI028749] 08/03/2001 Willie Lanier GLA [PI028750] 03/29/2000 Dan Goich GLA [PI030312] 09/18/2003 Tim Brown GLA [PI002819] Objections Response Court's Ruling 2220 2221 2222 2223 2224 2225 20202979.1 Dallas 258080v3 Dallas 266289v1 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2226 Description Various Dates Raider Reports [PI135609 PI139710] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Response Court's Ruling 20202979.1 Dallas 258080v3 Dallas 266289v1 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2227 Description Various Dates Raider Reports [PI139723 PI140217] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Response Court's Ruling 20202979.1 Dallas 258080v3 Dallas 266289v1 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2228 Description Various Dates Raider Reports [PI140218 PI140368] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Response Court's Ruling 20202979.1 Dallas 258080v3 Dallas 266289v1 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2229 Description Various Dates Raider Reports [PI091026 PI094483] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Response Court's Ruling 20202979.1 Dallas 258080v3 Dallas 266289v1 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2230 Description Various Dates Raider Reports [PI094484 PI094955] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Response Court's Ruling 20202979.1 Dallas 258080v3 Dallas 266289v1 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2231 Description Various Dates Raider Reports [PI094956 PI095073] Objections Hearsay: This are spreadsheets generated by Defendant that purport to show payments made to retired players from thirdparty licenses. Defendants' statements regarding the amounts earned by retired players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit provides the amounts that retired players were paid pursuant to ad hoc agreements, which does not affect whether retired players are entitled to an equal share royalty under the GLA. As a jury may be confused when faced with evidence of amounts retired players were paid under separate third-party agreements, the Court should exclude this exhibit. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Defendants' statements about their own financial positions are hearsay, and should be excluded. Hearsay: Defendants' statements about their own financial positions are hearsay, and should be excluded. Response Court's Ruling 2232 00/00/0000 EA Video Game Fee List [PI051545 PI051550] 03/01/2007 02/29/2008 NFLPA Annual Financial Report: 2007-2008 [PI140387 PI140443] 03/01/2004 02/28/2005 NFLPA Financial Statement: 20042005 [PI096088 PI096150] 2242 2243 20202979.1 Dallas 258080v3 Dallas 266289v1 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2244 Description 03/01/2003 02/29/2004 NFLPA Financial Statement: 20032004 [PI096151 PI096214] 03/01/2002 02/28/2003 NFLPA Financial Statement: 20022003 [PI096215 PI096276] 11/03/1994 Amended Bylaws of PI [PI139711 PI139721] 03/18/1991 Minutes of NFLPA Board of Player Directors' Meeting [PI096277] Objections Hearsay: Defendants' statements about their own financial positions are hearsay, and should be excluded. Hearsay: Defendants' statements about their own financial positions are hearsay, and should be excluded. Response Court's Ruling 2245 2246 2247 Hearsay: Any statements attributable to Defendants or third parties, including minutes from NFLPA board meetings, are hearsay and should be excluded. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. 20202979.1 Dallas 258080v3 Dallas 266289v1 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2248 Description 03/31/2008 Credited Seasons Listing [No Bates] Objections Hearsay: These are spreadsheets generated by Defendants that purport to show pension-credited seasons of active players. Defendants' statements regarding the number of seasons played by certain active players are hearsay. Authentication: The exhibit must be authenticated before Defendants can admit it into evidence. 403: this exhibit focuses on active players. The number of seasons credited to active players, for pension purposes, is not materially relevant to the merits of the remaining claims. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. 50 Response Court's Ruling 2249 2250 2251 2252 2253 00/00/0000 Reebok DeAngelo Hall Advertisement [PI141252 PI141253] 00/00/0000 Reebok - NFL Zone Advertisement [PI141254] 00/00/0000 Reebok - William Henderson, Najeh Davenport Advertisement [Pl141255 Pl141258] 00/00/0000 EA/Madden '06 Advertisement (video) [PI141259] 00/00/0000 Reebok Advertisement (video) [PI141260] 20202979.1 Dallas 258080v3 Dallas 266289v1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2254 Description 00/00/0000 Fathead Advertisement [PI141261] 00/00/0000 NFL Players.com Advertisement [PI141262 PI141263] 00/00/0000 NFL Players.com Advertisement [PI14l264 PI141265] Objections Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Any statements attributable to a third party are hearsay. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. Response Court's Ruling 2255 2256 2257 2258 00/00/0000 Reebok/Modell's Advertisement (video) [PI141266] 01/00/2006 Players Inc Brochure [PI140980 PI140983] 2259 09/00/2006 Players Inc Brochure [PI140996 PI140999] 20202979.1 Dallas 258080v3 Dallas 266289v1 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2260 Description 00/00/0000 Players Inc Brochure [No Bates] Objections Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Response Court's Ruling 2261 00/00/0000 Players Inc Brochure [No Bates] 2262 Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. 09/01/2003 Street Authentication: This & Smith's Sports exhibit must be Business Journal authenticated before Special Defendants can admit this Advertising into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. 00/00/0l000 Hard- Authentication: This Hitting Marketing exhibit must be Brochure [No authenticated before Bates] Defendants can admit this into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. Authentication: This exhibit must be authenticated before Defendants can admit this into evidence. Hearsay: Any statements attributable to Defendants or third parties are hearsay and should be excluded. Feature [No Bates] 2263 2264 00/00/0000 HardHitting Marketing Brochure [No Bates] 20202979.1 Dallas 258080v3 Dallas 266289v1 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP A T T O R N E Y S A T LAW LO S A N G E L E S Ex. No. 2265 Description 00/00/0000 Retired Players Video Game Payments [PI095700 PI095716] Objections Authentication: This compilation must be authenticated before Defendants can admit this into evidence. Hearsay: Defendants' statements regarding fees paid to various players are hearsay, and should be excluded. 403: this document appears to be a summary of "video game payments" for certain players. Evidence of payments pursuant to other agreements may confuse the jury as to whether the class members have been properly paid under the GLA, and has minimal probative value to the merits of the remaining claims, and should be excluded. Response Court's Ruling 2266 2267 2268 00/00/0000 Madden 2007 Screenshot Player Management 66 Packers CB#32 [

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