Parrish et al v. National Football League Players Incorporated

Filing 59

Declaration of Ryan S. Hilbert in Support of 57 Memorandum in Opposition, to Defendant's Motion to Transfer Venue filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3)(Related document(s) 57 ) (Hilbert, Ryan) (Filed on 5/10/2007)

Download PDF
Parrish et al v. National Football League Players Incorporated Doc. 59 Case 3:07-cv-00943-WHA Document 59 Filed 05/10/2007 Page 1 of 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 PALO A L T O 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 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 TO TRANSFER VENUE 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 TO TRANSFER VENUE CASE NO. C 07-0943 WHA Dockets.Justia.com Case 3:07-cv-00943-WHA Document 59 Filed 05/10/2007 Page 2 of 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 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 the NFL Players Association ("NFLPA") as it existed on May 8, 2007. 4. I am informed and believe that Doug Allen and Pat Allen, the former President and Executive Vice President of PLAYERS INC, respectively, reside at 542 N. Gardner Street, Los Angeles, California 90036. 5. I am also informed and believe that Howard Skall is a marketing manager in the According to its website at Football Division of Creative Artists Agency (CAA). www.caa.com, CAA is located at 2000 Avenue of the Stars, Los Angeles, CA 90067. 6. I have reviewed the LM-2 Form filed by the NFLPA in 2006. According to this report, Electronic Arts, which is headquartered in Redwood City, California, paid the NFLPA $33,487,103 in 2005. This report is available on the U.S. Department of Labor's website at www.dol.gov. 7. Attached hereto as Exhibit 2 is a true and correct printout regarding the median time intervals in months for trial in the various district courts. This printout is available at: http://www.uscourts.gov/caseload2006/tables/C05Mar06.pdf. 8. Attached hereto as Exhibit 3 is a true and correct printout from the website of PLAYERS INC as it existed on May 8, 2007. 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 20181278.1 2 DECLARATION OF RYAN S. HILBERT IN OPPOSITION TO MOTION TO TRANSFER VENUE CASE NO. C 07-0943 WHA

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?