Parrish et al v. National Football League Players Incorporated

Filing 475

Declaration of Molly Donovan in Support of 473 Letter Brief In Further Support of Defendants' Opposition to Plaintiffs' Motion In Limine No. 4 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) 473 ) (Padnos, Todd) (Filed on 10/17/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 475

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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 MOLLY DONOVAN IN SUPPORT OF DEFENDANTS' LETTER BRIEF, DATED OCTOBER 17, 2008

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Dewey & LeBoeuf LLP

Declaration of Molly Donovan In Support of Defendants' Letter Brief

Civ. Action No. C07 0943 WHA

Dockets.Justia.com

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

DECLARATION OF MOLLY DONOVAN I, Molly Donovan, 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 am admitted to practice before this Court pro hac vice. I make this Declaration in support of Defendants' letter brief, dated October 17, 2008. 2. I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 3. Attached hereto as Exhibit 1 is a true and correct copy of Am. Canoe Ass'n, Inc. v. D.C. Water & Sewer Auth., 306 F. Supp. 2d 30 (D.D.C. 2004). 4. Attached hereto as Exhibit 2 is a true and correct copy of 1-11 Standardized Civil Jury Instructions for the District of Columbia § 11.13 (LEXIS 2008). 5. Attached hereto as Exhibit 3 is a true and correct copy of 1-11 Standardized Civil Jury Instructions for the District of Columbia § 11.14 (LEXIS 2008). 6. Attached hereto as Exhibit 4 is a true and correct copy of 1-11 Standardized Civil Jury Instructions for the District of Columbia § 11.15 (LEXIS 2008). 7. Attached hereto as Exhibit 5 is a true and correct copy of 1010 Potomac Assocs. v. Grocery Manufacturers of Am., 485 A.2d 199 (D.C. 1984). 8. Attached hereto as Exhibit 6 is a true and correct copy of Am. First Investment Corp. v. Goland, 925 F.2d 1518 (D.C. Cir. 1991). /// /// /// /// /// ///

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Dewey & LeBoeuf LLP

Declaration of Molly Donovan In Support of Defendants' Letter Brief

Civ. Action No. C07 0943 WHA

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

9. Attached hereto as Exhibit 7 is a true and correct copy of Lamphier v. Washington Hosp. Center, 524 A.2d 729 (D.C. 1987). I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated: October 17, 2008

_________/s/_______________ Molly Donovan

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Declaration of Molly Donovan In Support of Defendants' Letter Brief

Dewey & LeBoeuf LLP

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