Parrish et al v. National Football League Players Incorporated

Filing 56

Declaration of Ryan S. Hilbert in Support of 55 Memorandum in Opposition,, to Defendant's Motion for Judgment on the Pleadings, or, in the Alternative, Request to File Second Amended Complaint filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Related document(s) 55 ) (Hilbert, Ryan) (Filed on 5/10/2007)

Parrish et al v. National Football League Players Incorporated

Doc. 56

Case 3:07-cv-00943-WHA

Document 56

Filed 05/10/2007

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

MANATT, PHELPS & PHILLIPS, LLP RONALD S. KATZ (Bar No. CA 085713) E-mail: [e-mail] RYAN S. HILBERT (California Bar No. 210549) E-mail: [e-mail] NOEL S. COHEN (California Bar No. 219645) E-mail: [e-mail] 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

BERNARD PAUL PARRISH and HERBERT ANTHONY ADDERLEY and WALTER ROBERTS III, on behalf of themselves and all others similarly situated, Plaintiffs,

CIVIL ACTION NO. C07 0943 WHA

vs.

DECLARATION OF RYAN S. HILBERT IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION FOR JUDGMENT ON THE PLEADINGS AND, IN THE ALTERNATIVE, REQUEST TO GRANT MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT

NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC., a Virginia corporation, Defendant. I, Ryan S. Hilbert, do hereby declare and certify as follows: 1. I have personal knowledge of the following facts, and if called as a witness,

could and would competently testify thereto. 2. I am an attorney at law, duly licensed to practice before all the courts of the State

of California, and I am an associate with the law offices of Manatt, Phelps & Phillips, LLP,

DECLARATION OF RYAN S. HILBERT IN OPPOSITION TO MOTION FOR JUDGMENT ON THE PLEADINGS CASE NO. C 07-0943 WHA

Dockets.Justia.com

Case 3:07-cv-00943-WHA

Document 56

Filed 05/10/2007

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MANATT, PHELPS & PHILLIPS, LLP
A T T O R N E Y S A T LAW PALO A L T O

attorneys of record for Plaintiffs in the above-entitled action. 3. Attached hereto as Exhibit 1 is a true and correct printout from the website of

Defendant PLAYERS INC as it existed on February 6, 2007. 4. Attached hereto as Exhibit 2 is a true and correct printout from the website of

Defendant PLAYERS INC as it existed on May 8, 2007. 5. by Plaintiffs. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on May 10, 2007. /s/Ryan S. Hilbert_______________ Ryan S. Hilbert Attached hereto as Exhibit 3 is a proposed Second Amended Complaint prepared

20181281.3

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DECLARATION OF RYAN S. HILBERT IN OPPOSITION TO MOTION FOR JUDGMENT ON THE PLEADINGS CASE NO. C 07-0943 WHA