Parrish et al v. National Football League Players Incorporated

Filing 658

Declaration of Ronald S. Katz in Support of 657 Response ( Non Motion ) filed byHerbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Related document(s) 657 ) (Katz, Ronald) (Filed on 11/5/2009)

Parrish et al v. National Football League Players Incorporated

Doc. 658

Case3:07-cv-00943-WHA Document658

Filed11/05/09 Page1 of 2

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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 RONALD S. KATZ IN SUPPORT OF CLASS COUNSELS' RESPONSE TO OBJECTIONS AND CLASS COUNSELS' OBJECTION TO PARTICIPATION BY NON-CLASS MEMBERS IN ANY PHASE OF THE SETTLEMENT PROCEEDINGS Date: Thursday, November 19, 2009 Time: 2:00 p.m. Judge: Honorable William H. Alsup Place: Courtroom 9, 19th Floor

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MANATT, PHELPS & PHILLIPS, LLP
ATTO RNEY S AT LAW PA L O A L T O

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KATZ DECL. ISO CLASS COUNSELS' RESPONSE RE OBJECTIONS CASE NO. C 07-0943 WHA

Dockets.Justia.com

Case3:07-cv-00943-WHA Document658

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MANATT, PHELPS & PHILLIPS, LLP
ATTO RNEY S AT LAW PA L O A L T O

I, Ronald S. Katz, declare as follows: 1. I am an attorney duly licensed to practice law before the Courts of the State of

California and am a counsel of record in this matter. I am a partner with the law firm of Manatt, Phelps and Phillips, LLP ("Manatt"), and I represented plaintiff Herbert Anthony Adderley and the certified class in this action from its onset. I am submitting this Declaration in support of Class Counsels' Response to Objections and Class Counsels' Objection to Participation by NonClass Members in any Phase of the Settlement Proceedings. 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. Attached as Exhibit A is a true and correct copy of the form letter Mr. Parrish

made available for download on the Internet as early as September 20, 2009. 3. Attached as Exhibit B is a true and correct copy of the Report of the Third Circuit

Task Force regarding the percentage of the fund approach. 4. Attached as Exhibit C is a true and correct copy of the draft settlement agreement

Class Counsel submitted to the Court on July 13, 2009. 5. Attached as Exhibit D is a true and correct copy of the amicus brief that Manatt,

Phelps & Phillips submitted on behalf of Herb Adderley and James "Jim" Brown in the matter of Keller v. Electronic Arts, Inc., Case No. CV-09-1967 CW (N.D. Cal. 2009). I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Signed this 5th day of November, 2009, at Palo Alto, California. ___/s/ Ronald S. Katz_________________ Ronald S. Katz

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KATZ DECL. ISO CLASS COUNSELS' RESPONSE TO OBJECTIONS CASE NO. C 07-0943 WHA