Parrish et al v. National Football League Players Incorporated

Filing 502

Letter Brief re 490 Letter Brief filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit A)(Related document(s) 490 ) (Katz, Ronald) (Filed on 10/21/2008)

Exhibit A

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FRISS - HIGHLY CONFIDENTIAL

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Q.

Have you met with any -- anyone on

behalf of the National Football League Players
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Association or Players, Inc. at any time in connection with this litigation in which we're taking the deposition?
A. No.

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Q.

Did you actually draft this

declaration or did someone draft it for you? A. Q. Someone drafted it for me. Did anyone draft it for you who was

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not employed by Topps or your counsel? A. Q. A. Yes. Who drafted it? It was an attorney for -- actually

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LeBoeuf Lamb the firm used to be, but I -- they made an initial draft, I made comments to the draft, a few rounds of comments and they ultimately finalized it.
Q. And how did you communicate your

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comments back to the lawyers at -- is it Dewey & LeBoeuf? MR. GREENSPAN: A. Yes. Yes.

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Q.

How did you communicate your
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