Parrish et al v. National Football League Players Incorporated

Filing 601

Declaration of Ian Papendick in Support of 600 Reply Memorandum, Defendants' Reply Brief in Further Support of Their Renewed Motion for Judgment as a Matter of Law filed byNational Football League Players Incorporated, National Football League Players Association. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9)(Related document(s) 600 ) (Padnos, Todd) (Filed on 12/26/2008)

Parrish et al v. National Football League Players Incorporated

Doc. 601

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

Todd Padnos (Bar No. 208202) [e-mail] DEWEY & LEBOEUF LLP One Embarcadero Center, Suite 400 San Francisco, CA 94111 Tel: [phone]; Fax: [phone] Jeffrey L. Kessler (pro hac vice) [e-mail] David G. Feher (pro hac vice) [e-mail] David Greenspan (pro hac vice) [e-mail] DEWEY & LEBOEUF LLP 1301 Avenue of the Americas New York, NY 10019 Tel: [phone]; Fax: [phone] Kenneth L. Steinthal (pro hac vice) [e-mail] WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Tel: [phone]; Fax: [phone] Bruce S. Meyer (pro hac vice) [e-mail] WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Tel: [phone]; Fax: [phone] Attorneys for Defendants National Football League Players Association and National Football League Players Incorporated d/b/a Players Inc UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY, WALTER ROBERTS III, Plaintiffs, v. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a/ PLAYERS INC, Defendants. Case No. C 07 0943 WHA DECLARATION OF IAN PAPENDICK IN SUPPORT OF DEFENDANTS' REPLY BRIEF IN FURTHER SUPPORT OF THEIR RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW

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Dewey & LeBoeuf LLP

Declaration of Ian Papendick in Support of Defendants' Reply Brief in Further Support of Motion for JMOL

Civ. Action No. C07 0943 WHA

Dockets.Justia.com

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One Embarcadero Center, Suite 400 San Francisco, CA 94111

DECLARATION OF IAN PAPENDICK I, Ian Papendick, hereby declare as follows: 1. I am an attorney with Dewey & LeBoeuf LLP, attorneys for Defendants National Football League Players Association ("NFLPA") and National Football League Players Incorporated d/b/a Players Inc ("Players Inc") in this action. I am a member of the bar of the State of New York and am admitted to practice before this Court pro hac vice. I make this Declaration in support of Defendants' Reply Brief in Further Support of Their Renewed Motion for Judgment as a Matter of Law. I have personal knowledge of each of the facts stated herein, and if called to testify, could and would testify completely hereto. 2. Attached hereto as Exhibit 1 is a true and correct copy of the Jury's Special Verdict Form (Rec Doc. 561) (Nov. 11, 2008). 3. Attached hereto as Exhibit 2 are true and correct copies of excerpts of the transcript of trial proceedings, dated October 15, 2008-November, 10, 1008. 4. Attached hereto as Exhibit 3 is a true and correct copy Trial Exhibit 1217. 5. Attached hereto as Exhibit 4 is a true and correct copy of Trial Exhibit 1218. 6. Attached hereto as Exhibit 5 is a true and correct copy of Trial Exhibit 1221. 7. Attached hereto as Exhibit 6 is a true and correct copy of the first page of Trial Exhibit 2056. 8. Attached hereto as Exhibit 7 is a true and correct copy of "Order Denying Lehman's Motion for Judgment as a Matter of Law, Denying Lehman's Motion for New Trial, and Denying Lehman's Motion for Remittitur," No. SACV 01-971 DOC (C.D. Cal. April 13, 2004). 9. Attached hereto as Exhibit 8 is a true and correct copy of Trial Exhibit 1320. 10. Attached hereto as Exhibit 9 is a true and correct copy of Trial Exhibit 110. Dated: December 26, 2008

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Dewey & LeBoeuf LLP

____/s/_Ian Papendick_____ Ian Papendick

Declaration of Ian Papendick in Support of Defendants' Reply Brief in Further Support of Motion for JMOL

Civ. Action No. C07 0943 WHA