Parrish et al v. National Football League Players Incorporated

Filing 700

RESPONSE to re 699 Order -- Class Counsels' and Defendants' Response to July 12, 2010 Order by Herbert Anthony Adderley. (Attachments: # 1 Declaration of Lewis T. LeClair, # 2 Declaration of Jennifer M. Keough)(Katz, Ronald) (Filed on 7/19/2010)

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Parrish et al v. National Football League Players Incorporated Doc. 700 Att. 1 1 2 3 4 5 6 7 8 9 10 A PROFESSIONAL CORPORATION · ATTORNEYS MANATT, PHELPS & PHILLIPS, LLP RONALD S. KATZ (Bar No. CA 085713) E-mail: rkatz@manatt.com RYAN S. HILBERT (California Bar No. 210549) E-mail: rhilbert@manatt.com NOEL S. COHEN (California Bar No. 219645) E-mail: ncohen@manatt.com 1001 Page Mill Road, Building 2 Palo Alto, CA 94304-1006 Telephone: (650) 812-1300 Facsimile: (650) 213-0260 McKOOL SMITH, P.C. LEWIS T. LECLAIR (Bar No. CA 077136) E-mail: lleclair@mckoolsmith 300 Crescent Court, Suite 1500 Dallas, TX 75201 Telephone: (214) 978-4000 Facsimile: (214) 978-4044 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, Plaintiff 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 LEWIS T. LeCLAIR IN SUPPORT OF RESPONSE TO JULY 12, 2010 ORDER 11 12 13 DALLAS, TEXAS MCKOOL SMITH 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dallas 304717v2 Dallas 305333v1 DECLARATION OF LEWIS T. LeCLAIR ­ Page 1 Civil Action No. C07 0943 WHA Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 A PROFESSIONAL CORPORATION · ATTORNEYS LEWIS T. LeCLAIR declares: I am an attorney and a member of the bar of the State of California. I am a shareholder at the law firm of McKool Smith, P.C. in Dallas, and served as lead counsel for my firm and cocounsel for plaintiff Herb Adderley and the certified class in this action. I am submitting this declaration in support in support of Class Counsels' and Defendants' Response to July 12, 2010 Order. 1. On November 11, 2008, the Class Members received a jury verdict in the amount of $28.1 million. The verdict received a significant amount of media attention. 2. On July 14, 2010, following the Court's most recent Order, I met and conferred 11 12 13 DALLAS, TEXAS with one of the counsel for Defendants pursuant to the Court's July 12, 2010 Order. During the conversation, I asked whether Defendants could provide Class Counsel with the social security number for each Class Member who has yet to receive his share of the Settlement Fund. The purpose of the information would be to allow the Claims Administrator to run additional searches to locate each Class Member's current address. Defendants' counsel agreed to provide the Claims Administrator through Class Counsel with the information for such purpose. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed July 19, 2010 in Dallas, Texas. /s/ Lewis T. LeClair 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. 300125805.1 MCKOOL SMITH 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF LEWIS T. LeCLAIR ­ Page 2 Civil Action No. C07 0943 WHA Dallas 304717v2 Dallas 305333v1

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