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)
Parrish et al v. National Football League Players Incorporated
Doc. 59
Case 3:07-cv-00943-WHA
Document 59
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: 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
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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 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
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DECLARATION OF RYAN S. HILBERT IN OPPOSITION TO MOTION TO TRANSFER VENUE CASE NO. C 07-0943 WHA
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