Richard Dent, et al v. National Football League

Filing 100

REQUEST TO NFL FOR FURTHER SUBMISSION. Signed by Judge Alsup on 12/3/2014. (whalc2, COURT STAFF) (Filed on 12/3/2014)

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1 2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 11 For the Northern District of California United States District Court 10 12 13 14 RICHARD DENT, JEREMY NEWBERRY, ROY GREEN, JD HILL, KEITH VAN HORNE, RON STONE, RON PRITCHARD, JAMES MCMAHON, MARCELLUS WILEY, and JONATHAN REX HADNOT, on behalf of themselves and all others similarly situated, 15 16 17 No. C 14-02324 WHA REQUEST TO NFL FOR FURTHER SUBMISSION Plaintiffs, v. 18 NATIONAL FOOTBALL League, a New York unincorporated association, 19 Defendant. / 20 21 In connection with its Section 301 argument, the NFL has argued that plaintiffs are not 22 without remedies under the CBAs but, other than to say claims could be initiated, grievable, or 23 arbitrable, the NFL does not explain the extent to which, if the claims alleged are true, any 24 plaintiff could have stated a claim under one or more CBAs. 25 Therefore, the NFL is requested to be specific and answer the following question: 26 If all the abuses alleged by the clubs and club physicians in the operative complaint could 27 be proven, what remedies would the players injured by such abuses have had under specific 28 clauses of the CBAs against their clubs, assuming timely grievances and/or arbitration were 1 initiated? The Court wishes to know the full extent to which the NFL specifically concedes that 2 any CBA provision would have been grievable and what the remedies under the CBAs would be. 3 4 The NFL is requested to respond in ten pages or less by NOON ON DECEMBER 5, 2014. Plaintiffs shall respond in ten pages or less by NOON ON DECEMBER 8, 2014. 5 6 7 Dated: December 3, 2014. WILLIAM ALSUP UNITED STATES DISTRICT JUDGE 8 9 11 For the Northern District of California United States District Court 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

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