Parrish et al v. National Football League Players Incorporated

Filing 666

Declaration of Ryan S. Hilbert in Support of 665 Response ( Non Motion ) filed byHerbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 665 ) (Katz, Ronald) (Filed on 11/18/2009)

Parrish et al v. National Football League Players Incorporated

Doc. 666

Case3:07-cv-00943-WHA Document666

Filed11/18/09 Page1 of 2

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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] 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 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 RYAN S. HILBERT IN SUPPORT OF CLASS COUNSELS' RESPONSE TO NOVEMBER 17, 2009 ORDER

DECLARATION OF RYAN S. HILBERT CASE NO. C 07-0943 WHA

Dockets.Justia.com

Case3:07-cv-00943-WHA Document666

Filed11/18/09 Page2 of 2

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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

I, Ryan S. Hilbert, 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 an associate with the law firm of Manatt, Phelps and Phillips, LLP ("Manatt"), co-counsel for plaintiff Herb Adderley and the certified class in this action. I am submitting this Declaration in support of Class Counsels' response to the Court's November 17, 2009 Order. 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 hereto as Exhibit A is a true and correct copy of Plaintiffs' First Set of

Interrogatories to Defendant National Football League Players Association, dated November 20, 2007. 3. Attached hereto as Exhibit B is a true and correct copy of National Football

League Players Association's Responses to Plaintiffs' First Set of Interrogatories, dated December 20, 2007. 4. Attached hereto as Exhibit C is a true and correct copy of an email sent by

Defendants' counsel on October 16, 2008 regarding trial Exhibit 2057. 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 18th day of November, 2009, at Palo Alto, California.

______________________ Ryan S. Hilbert

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DECLARATION OF RYAN S. HILBERT CASE NO. C 07-0943 WHA