Parrish et al v. National Football League Players Incorporated

Filing 655

Declaration of Herbert Anthony Adderley in Support of 652 MOTION for Settlement -- Notice of Motion and Motion for Final Approval of Settlement and of Proposed Plan of Distribution filed byHerbert Anthony Adderley. (Attachments: # 1 Exhibit A)(Related document(s) 652 ) (Katz, Ronald) (Filed on 10/15/2009)

Parrish et al v. National Football League Players Incorporated

Doc. 655

Case3:07-cv-00943-WHA Document655

Filed10/15/09 Page1 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
ATTO RNEY S AT LAW PA L O 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] MCKOOL SMITH, P.C. LEWIS T. LECLAIR (Bar No. CA 077136) E-mail: [e-mail] JILL ADLER NAYLOR (Bar No. CA 150783) E-mail: [e-mail] 300 Crescent Court Dallas, TX 75201 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

HERBERT ANTHONY ADDERLEY, on behalf of himself and all others similarly situated, Plaintiffs, vs. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, a Virginia corporation, and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC., a Virginia corporation, Defendants.

CIVIL ACTION NO. C07 0943 WHA DECLARATION OF HERBERT ANTHONY ADDERLEY IN SUPPORT OF MOTION FOR FINAL APPROVAL OF SETTLEMENT AND OF PROPOSED PLAN OF DISTRIBUTION Date: Thursday, November 19, 2009 Time: 2:00 p.m. Judge: Honorable William H. Alsup Place: Courtroom 9, 19th Floor

20210136.1

1

ADDERLEY DECL. ISO MOTION FOR FINAL APPROVAL OF SETTLEMENT CASE NO. C 07-0943 WHA

Dockets.Justia.com

Case3:07-cv-00943-WHA Document655

Filed10/15/09 Page2 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
ATTO RNEY S AT LAW PA L O A L T O

I, Herbert Anthony Adderley, declare as follows: 1. I am a party to this lawsuit. I am submitting this Declaration in support of Class

Counsels' motion for final approval of the settlement agreement. The following declaration is based upon my personal knowledge. If called as a witness I could and would competently testify to the facts set forth herein. 2. I am a retired professional football player who played for more than 10 years in the

National Football League ("NFL") for the Green Bay Packers and the Dallas Cowboys. I was elected to be a member of the professional football Hall of Fame in 1980. 3. I have been a party to this case since it was first filed in February 2007. I was

deemed to be an adequate class representative on April 29, 2009 and served as the Class Representative for the GLA Class from the moment the class was certified. 4. I have previously submitted several declarations in this case. On November 26,

2008, I submitted a declaration explaining the amount and type of work I did in my role as Class Representative. A copy of my November 26, 2008 Declaration is attached hereto as Exhibit A. 5. I have reviewed the settlement agreement and am familiar with its terms. I have

also spoken with Class Counsel about it. In my opinion, the settlement agreement represents a tremendous accomplishment on behalf of the GLA Class, especially since the Class Members will be receiving $26,250,000 (which is a just a little less than the $28,100,000 awarded by the jury) without the risk and uncertainty of continued litigation. I believe that the settlement agreement is in the best interest of the GLA Class. 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 October 15, 2009.

/s/ Herbert Anthony Adderley Herbert Anthony Adderley Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Ronald S. Katz hereby attests that concurrence in the filing of this document has been obtained.

20210136.1

2

ADDERLEY DECL. ISO MOTION FOR FINAL APPROVAL OF SETTLEMENT CASE NO. C 07-0943 WHA