Parrish et al v. National Football League Players Incorporated

Filing 64

Declaration of Ronald S. Katz in Support of 63 Reply to Opposition Supplemental Declaration of Ronald S. Katz in Support of Plaintiffs' Reply in Support of Motion to Appoint Manatt, Phelps & Phillips, LLP as Interim Class Counsel filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Related document(s) 63 ) (Katz, Ronald) (Filed on 5/17/2007)

Parrish et al v. National Football League Players Incorporated

Doc. 64

Case 3:07-cv-00943-WHA

Document 64

Filed 05/17/2007

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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 SAN FRANCISCO DIVISION

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

CIVIL ACTION NO. C07 0943 WHA

NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC, a Virginia corporation, Defendant.

SUPPLEMENTAL DECLARATION OF RONALD S. KATZ IN SUPPORT OF PLAINTIFFS' REPLY IN SUPPORT OF MOTION TO APPOINT MANATT, PHELPS & PHILLIPS, LLP AS INTERIM CLASS COUNSEL Date: May 31, 2007 Time: 8:00 a.m. Judge: William Alsup

I, Ronald S. Katz, declare and state as follows: 1. I am an attorney at Manatt, Phelps & Phillips, LLP and am one of the

lawyers responsible for the representation of Plaintiffs Herbert Anthony Adderley, Bernard Paul Parrish and Walt Roberts III, on behalf of themselves and others similarly situated ("Plaintiffs")

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SUPP. DECL. OF RONALD S. KATZ CASE NO. C07 0943 WHA
Dockets.Justia.com

Case 3:07-cv-00943-WHA

Document 64

Filed 05/17/2007

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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

in this matter. I have personal, first-hand knowledge of the matters stated herein, and, if called upon to do so, I could and would competently testify thereto. 2. Contrary to Defendant's allegations in its Corrected Opposition to

Plaintiffs' Motion to Appoint Interim Class Counsel at pp. 2, 5 and 9, I am not nor have I ever been an officer or director of Retired Professional Football Players for Justice ("RPFPJ"), nor have I ever been identified as such by that organization. 3. I am identified as "Outside Litigation Counsel" for RPFPJ on its website,

and that is my only association with that organization. It is a potential association because that organization is not currently engaging in and has never engaged in any litigation. 4. Contrary to Defendant's allegations in its Corrected Opposition to

Plaintiffs' Motion to Appoint Interim Class Counsel at pp. 8 and 9, I did not play a "leading role in establishing Retired Players for Justice." I am not a founder of that organization. 5. Contrary to Defendant's allegations in its Corrected Opposition to

Plaintiffs' Motion to Appoint Interim Class Counsel at p. 12, I am not acting "with the apparent improper purpose of advancing the agenda of a non-class member, Parrish, in his long-running campaign against the NFLPA." At his request, I am representing Mr. Parrish and others in this lawsuit, which I believe, as a result of my investigation and research described in my earlier declaration supporting this Motion, is well-founded in fact and in law. I have not been retained for any purpose other than this lawsuit. 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 17, 2007, at Palo Alto, California. /s/Ronald S. Katz____________________ Ronald S. Katz
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SUPP. DECL. OF RONALD S. KATZ CASE NO. C07 0943 WHA