Parrish et al v. National Football League Players Incorporated

Filing 58

Declaration of Walter Roberts III in Support of 57 Memorandum in Opposition, in Support of Plaintiffs' Opposition to Defendant's Motion to Transfer Venue filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Related document(s) 57 ) (Hilbert, Ryan) (Filed on 5/10/2007)

Parrish et al v. National Football League Players Incorporated

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Doc. 58

Case 3:07-cv-00943-WHA
05/08 / 2007 06:51 089725143

Document 58

Filed 05/10/2007
OSTAL ANNEX

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NO;-L S. COHEN (California Bar No. 219645) E-rrail: [e-mail] 1001. Page Mill Road, Bi ild ng 2 Pala Alto, CA. 94304-1006 5 Telf:phone: [phone] Fac;itnile. (6503) 213-0260 6
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PHILLIPS, LLP RONA LD S, KATZ (Bat No. CA 085713) E-mail: rjcatz1@ i-nanatt.com RYAN S. ALBERT (Califlantia Bar No. 210549) E-n. ail.: [e-mail]-0.

M- ANATT, PEELPS

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Attorneys for Plaintiffs,

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UNITED STATES DISTRICT COURT NORTH-RN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

BF1,NARD PAUL P.A.RR.ISH w.d IJERBERT ANTHONY ADDERLEY and W) kLTER ROBERTS 111, on behalf of the mselves and all others sinmilarly situated, Plaineft

CIVIL ACTION NO. C07 0943 WHA

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DECLARATION OF WAL'T'ER ROBERTS MIN SUPPORT OF PLAE i[+'S' OPFOSMON TO DEFENDAN r S MOT (ON TO 1RA SEER VENUE

vs.

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N, MONAL FOOTBALL LEAGUE PLAYERS INCORPORATED dIb/a
PLAYERS TNC., a Virginia corporation,

Defendant.

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MANATT, FYAiLP9 A ^ Pita LLIM, L,LP

I, Walter Roberts 111, declare and state as follows:
1. am a party to this lawsuit. and subi-ait this declaration in support of Plaintif fs '

Uppositi.on to Defendant' s Motion to Transkr Venue. I have personal, first-hand .knowledge of thi, matters stated herein, and, if called upon to do so, I could grid would competently testify

ECLARA17MTOrWALTER RO$EATSM W TMnQTTTnW Tn MrnrMW Tr) ru n AagxPu u uvrm

Dockets.Justia.com

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Case 3:07-cv-00943-WHA
05/08/2007 06;51 089725143

Document 58

Filed 05/10/2007
OSTAL ANNEX

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her,,to. I was a wide receiver and kick returner in the NFL from 1.964 to 1970.During this tiara,

2 1 ply yed with the Cleveland Browns from 1964 to 1966 and was a member of the Cleveland. 3 ro rvns team that defeated Jobnn.y Unitas and Coach Dozy, Shula's 13altbrore Colts 27--4 in the

4 1964 World, Dampionship. 5
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ollowing my stint with the Browns. I played with the New Orleans Saints during

their inaugural season in 1967 and helped the Saints aria their -first game in fratxchise history by sco ring three toucbdovms in a 31-24 victory Aver the Philadelphia Eagles. I also played for Coach Vince Lombardi. and the Washington Redskins in 1969 and 1970. 3. , utting aside wytime playing professional football, I have been a resident of

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Cad ifornia since I was nine years old. 1 have been a resident of Northern California. since about 19"9. T currvtly, live in San Jose, California, Any doc-Lunents I have that are related to this case are located there. 4. n my senior year at Compton Fligli School .in Compton, California in 1960, I was

' Cart ornia state and national long jump cbmnpion. Following high school, I attended San Tose St .te for four years. I loll San lose State it) 1964 to begin my pzofessional football career.
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ollowing my professional fvvtball career, I returned to Southern California in

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1911 before movb to Northern. California in 1, 979. In the early 1980s, I co-founded a building supplies company called A Builders Specialties, Inc. This company, which was located on Third A.` euue in San Mateo, California, remained in business until 1988 or 1989, 6.
For

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ince 1988 or 1989, I have worked in various jobs throughout Northern California.

example, I have worked, and continue to work, part-time as a carrier for the Saxe Francisco

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Uxonicle. I currently Nvork for the Chronicle every day from 3:30 a.nL to 6:34 a.m. There is cII rrently only one other person who has been trained to perform nay Specific job with the Cbronicle. It would be difficult for me to travel to the East Coast in connection with this case, because I would have to make sure that that person was avallablo to work for me in my absence.

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MANATT, PHT..LL'$ $ PHILLIN, LL?=' tl ECLAFFCMN W WALTER t2 )M_ZT8 M IN '1 1S^P/7RTTTf"1ih: `i`fFtAflT7f"f1+7 Yf1YA RAICS 'IC17 17FVfTA

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Case 3:07-cv-00943-WHA
05/0812007 06:51 089725143

Document 58

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OSTAL ANNEX

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declare under penalty of perjury under the laws of the United States that the foregoing is

2 true and correct and that ibis declaration was executed on May9 , 2007.
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Walter Roberts III
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2-S .;vAMATT, PraFi,ae SY [nu.[ns,ZI MCLARAT4NOF WALTER R4EERT3MIN ,a,YngM0'mTTnh40TTr1Rr rii 1VATS PR Vr.WTM