JENKINS et al v. NATIONAL COLLEGIATE ATHLETIC ASSOCIATION et al

Filing 111

ORDER by Judge Claudia Wilken Granting (186) in case 4:14-md-02541-CW; (110) in case 4:14-cv-02758-CW STIPULATION REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN OTHER CASES. (ndr, COURT STAFF) (Filed on 1/8/2015)

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

1 BRUCE L. SIMON (Bar No. 96241)
[e-mail]
2 AARON M. SHEANIN (Bar No. 214472)
[e-mail]
3 BENJAMIN E. SHIFTAN (Bar No. 265767)
[e-mail]
4 PEARSON, SIMON & WARSHAW, LLP
44 Montgomery Street, Suite 2450
5 San Francisco, California 94104
Telephone: [phone]
6 Facsimile: [phone]
7 STEVE W. BERMAN (pro hac vice)
[e-mail]
8 HAGENS BERMAN SOBOL SHAPIRO LLP
1918 Eighth Avenue, Suite 3300
9
Seattle, WA 98101
10 Telephone: [phone]
Facsimile: [phone]
11
Additional Counsel on Signature Page
12
Plaintiffs’ Interim Co-Lead Class Counsel
13
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UNITED STATES DISTRICT COURT
15
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
16
17
IN RE: NATIONAL COLLEGIATE
18 ATHLETIC ASSOCIATION ATHLETIC
GRANT-IN-AID CAP ANTITRUST
19 LITIGATION
20

CASE NO. 14-md-2541-CW
CASE NO. 4:14-cv-02758-CW
STIPULATED [PROPOSED] ORDER
REGARDING PRODUCTION OF
DOCUMENTS FROM CERTAIN OTHER
CASES

21 This Document Relates to:
22 ALL ACTIONS
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14-md-2541-CW; 4:14-cv-02758
STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

WHEREAS the instant multidistrict litigation (the "Instant Actions") involves certain

1

2 factual and legal issues which may have been the subject of certain documents and other materials
3 produced and/or exchanged in the following actions: (1) O'Bannon v. NCAA, Case No. 09-cv4 3329-CW (N.D. Cal.);1 (2) White v. NCAA, Case No. 06-cv-0999-VBF (C.D. Cal.); (3) Agnew v.
5 NCAA, Case No. 11-3066 (7th Cir.)/Agnew v. NCAA, Case No. 11-cv-0293-JMS (S.D. Ind.); and
6 (4) Rock v. NCAA, Case No. 12-cv-1019-JMS (S.D. Ind.) (the “Past NCAA Actions”).
WHEREAS, without acknowledging or agreeing that such documents and other materials

7

8 are relevant or discoverable in the Instant Actions, Defendants are willing to re-produce those
9 portions of the documents produced in the Past NCAA Actions (the “Documents”), and Plaintiffs

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

10 are willing to limit the extent to which they may serve additional requests on Defendants for
11 documents on the basis that such documents were produced, exchanged, or filed in any of the Past
12 Actions, thereby limiting the obligation on the NCAA to engage in a costly and time-consuming
13 review of several hundred thousand duplicative documents and on the other defendants to gather,
14 review and reproduce duplicative documents.
WHEREAS, the NCAA has agreed, pursuant to the terms herein, to produce in the Instant

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16 Actions certain additional materials from the Past NCAA Actions that it may have in its
17 possession, including: the NCAA’s expert reports; the NCAA's discovery responses; NCAA18 witness and/or any Conference Defendant’s deposition transcripts, videos, and exhibits; NCAA
19 and/or any Conference Defendant’s declarations and affidavits; and trial transcripts and trial
20 exhibits from the Past NCAA Actions (“Materials”);
WHEREAS, the Defendants agree, pursuant to the terms herein, to provide to Plaintiffs the

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22 Documents, and the NCAA agrees to provide to Plaintiffs the Materials, set forth below beginning
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1

The O’Bannon litigation was at one time consolidated with Keller v. Electronic Arts, Inc. as In re
NCAA Student-Athlete Name & Likeness Litig., Case No. 09-cv-1967-CW (N.D. Cal.) and then
25 severed for purposes of trial. All discovery was conducted in connection with the O’Bannon
litigation prior to severance—no separate document production was made in Keller v. NCAA.
26 There are no previous document productions from the Keller v. NCAA litigation to reproduce in
this case.
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24

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14-md-2541-CW; 4:14-cv-02758-CW
2
STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

1 as soon as processing time will allow and a Stipulated Protective Order is entered in the Instant
2 Actions.
3

WHEREAS, the Parties have agreed to treat the Documents and Materials to be produced

4 as “Confidential,” “Highly Confidential” or “Outside Counsel Only” as their designations in
5 connection with their production in the Past NCAA Actions may require, in conformity with the
6 Protective Order to be entered in the Instant Actions, without the Defendants having to review
7 those designations, so as to avoid imposing on the Defendants a costly re-review of previously
8 produced documents for confidentiality.
9

WHEREAS, in entering into this Stipulation, no party takes a position concerning the

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

10 relevance or discoverability of any of the Documents or Materials, and the parties preserve all
11 rights to object to the use of the Documents and Materials in this litigation on grounds including,
12 but not limited to, relevance and admissibility.
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THEREFORE, the parties hereby stipulate and agree to the following:

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1) The Defendants will reproduce Documents and the NCAA will produce Materials as

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set forth below from the Past NCAA Actions as provided and subject to the terms and

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limits set forth herein, as soon as processing time will reasonably allow and a

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Stipulated Protective Order is entered in the Instant Actions.

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2) The Defendants' reproductions of Documents from the Past NCAA Actions will be

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limited to documents that date from March 5, 2010 to the present, with the exception of

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the document production from the White v. NCAA and the O’Bannon v. NCAA

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litigation.

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3) White v. NCAA: The NCAA will reproduce the document production from the White

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litigation, as it was reproduced as part of the Rock v. NCAA production in early 2014.

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The NCAA will also produce from the White litigation NCAA written discovery

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responses, transcripts of NCAA witness depositions; and subject to Paragraph 8,

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below, its expert reports and any remaining Materials in its possession, custody and

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control based on a reasonable investigation.

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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4) O’Bannon v. NCAA: The NCAA will reproduce the NCAA’s document productions

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from the O’Bannon litigation. The NCAA will also produce from the O'Bannon

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litigation NCAA written discovery responses, and transcripts of NCAA witness

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depositions, and subject to Paragraph 8, below, its expert reports and any remaining

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Materials.

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5) Agnew v. NCAA: The only documents produced in the Agnew v. NCAA case prior to its

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dismissal for failure to state a claim were also reproduced in Rock v. NCAA. The

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NCAA will make any reproduction of documents from the Agnew case in the course of

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the reproduction of documents from the Rock case discussed in Paragraph 6, below.

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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6) Rock v. NCAA: The NCAA will produce NCAA written discovery responses and

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transcripts of NCAA witness depositions from Rock v. NCAA. The NCAA will also

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produce the following documents from the NCAA’s document production in Rock v.

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NCAA:

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a. All squad lists, re-processed to eliminate the previous redaction of men’s and
women’s basketball squad lists;

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b. All supplemental productions dated after August 1, 2014; and

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c. Additional documents from the pre-August 1, 2014 NCAA productions in Rock

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with a “last modified” date of March 5, 2010 to the present, to the extent those

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documents contain hits on the following search terms ("Other NCAA Case

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Documents Search Terms"):

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1. amateur! AND (GIA OR “grant in aid” OR grant-in-aid OR COA OR

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“cost of attendance” OR cost-of-attendance OR scholarship OR aid OR

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award OR benefit)

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2. commercial! AND (GIA OR “grant in aid” OR grant-in-aid OR COA

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OR “cost of attendance” OR cost-of-attendance OR scholarship OR aid

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OR award OR benefit)

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3. cap! AND (GIA OR “grant in aid” OR grant-in-aid OR COA OR “cost
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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of attendance” OR cost-of-attendance OR scholarship OR aid OR award

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OR benefit)

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4. limit! AND (GIA OR “grant in aid” OR grant-in-aid OR COA OR “cost

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of attendance” OR cost-of-attendance OR scholarship OR aid OR award

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OR benefit)

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5. (SA OR student-athlete) AND (GIA OR “grant in aid” OR grant-in-aid

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OR COA OR “cost of attendance” OR cost-of-attendance OR

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scholarship OR aid OR award OR benefit)

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

6. (SA OR student-athlete) AND (salary OR pay! OR union! OR employ!

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44 MONTGOMERY STREET, SUITE 2450

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OR agent OR well-being OR exploit! OR induce! OR certification OR

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boosters)

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7. (“cost of attendance” OR cost of attendance OR COA) AND (“grant in
aid” OR grant-in-aid” OR GIA)
8. bylaw AND (12! OR 13! OR 15! OR 16! OR 20!) AND (amateur! OR

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GIA OR “grant in aid” OR grant-in-aid OR COA OR “cost of

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attendance” OR cost-of-attendance OR scholarship OR aid OR award

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OR benefit)

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9. compet! AND (balance OR equity OR fair)

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10. “collegiate model”

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11. pay-for-play

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12. “pay for play”

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13. avocation

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14. “miscellaneous expense allowance”

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15. MEA

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16. stipend

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17. 2011-96

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18. “presidential retreat”

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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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19. “rules working group”

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20. “well-being working group”

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21. “resource allocation working group”

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22. governance AND autonomy

treated as “Outside Counsel Only,” to protect NCAA member confidential

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information from being inadvertently distributed to conference defendants.

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7) Conference Defendant Documents: Each of the ten Conference Defendants in the

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SAN FRANCISCO, CALIFORNIA 94104

Confidential” will be re-designated to provide that the documents must be

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PEARSON, SIMON & WARSHAW, LLP

d. NCAA documents produced in Rock v. NCAA with a designation of “Highly

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44 MONTGOMERY STREET, SUITE 2450

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Instant Actions will reproduce all Documents produced to the plaintiffs in the Past

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NCAA Actions by such Conference Defendant, in the forms in which they were

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previously produced (including redactions).

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8) Third Party Documents and Materials:  
a. The NCAA will ask each of its member schools and non-defendant conferences

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that produced documents in discovery or trial in the Past NCAA Actions

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subject to a confidentiality order in such actions to indicate by January 15,

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2015 whether it will consent to production of such documents and/or

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information in the Instant Actions subject to a confidentiality order in the

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Instant Actions and, if a school or conference refuses, to state the reasons for its

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refusal to grant such consent;  

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b. The NCAA will provide, to the best of its ability based on available records, a

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list of all non-NCAA member third parties that produced documents in

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discovery in the Past NCAA Actions subject to a confidentiality order in such

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actions, and Plaintiffs will request the consent of those third parties for the

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production of such documents in this action;  

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c. The NCAA will then, to the extent Plaintiffs obtain the consent of the relevant
third parties, produce unredacted versions of any Documents and Materials it
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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previously had redacted based on those third parties' confidential information

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and any Documents and Materials it previously had withheld based on those

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third parties' confidential information, with the exception of confidential

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information referenced in subparagraphs a and b above for such third parties

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who have not provided consent; and 

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d. Plaintiffs reserve the right to file a motion to compel the production of any

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confidential Materials for any persons who have not consented to the

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production of such Materials. 

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9) In exchange for the above-described reproductions of documents and other materials,

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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the parties agree that the Conference Defendants will have no obligation to produce

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copies of the Materials which are produced by the NCAA (if and to the extent that the

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Conference Defendants have copies of such Materials) in accordance with this

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stipulation.

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10) The parties agree to accept the reproductions of the Defendants’ documents in the

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production formats in which they are available and/or were produced in the Past

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NCAA Actions, even if that format differs from any agreed ESI Production protocol

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that may be entered in this litigation.

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11) As a part of the reproduction of Documents to occur as provided herein, the NCAA

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will provide, where technologically feasible, as metadata, a field listing the production

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bates number of the documents being reproduced, as they were labeled when produced

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in the prior case.

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12) All reproduced documents will be re-bates labeled using the prefix “[Defendant

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initials]GIA.” Defendant-produced documents with other bates-labels will not be used

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in the litigation.

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13) The Defendants will not reproduce documents produced by other parties in past
litigations or by third-parties, except as set forth herein.
14) The parties agree that Defendants’ production of Documents and Materials pursuant to
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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this Stipulation will satisfy their obligations to produce documents in response to

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request numbers 25 and 26 of Jenkins Plaintiffs’ First Set of Requests for Production of

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Documents to All Defendants and request number 26 of Consolidated Plaintiffs First

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Set of Requests for Production of Documents to All Defendants. This Stipulation does

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not limit plaintiffs’ ability to seek documents that are independently responsive to any

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other requests for documents served by plaintiffs in the Instant Actions, regardless of

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whether such documents previously were produced in the Past Actions. If, however, a

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document responsive to a separate document request was previously produced by a

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Defendant in the Instant Actions pursuant to this Stipulation, that Defendant need not

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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produce that document a second time in the Instant Actions due to its responsiveness to

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the separate document request. Plaintiffs further agree that they will not serve

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additional requests for documents on the basis that such documents were produced,

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exchanged, or filed in any of the Past Actions.

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IT IS SO STIPULATED.

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

1 DATED: January 7, 2015

HAGENS BERMAN SOBOL SHAPIRO LLP

2

By: /s/ Steve W. Berman
STEVE W. BERMAN

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1918 Eighth Avenue, Suite 3300
Seattle, WA 98101
Telephone: [phone]
[e-mail]

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Jeff D. Friedman (Bar. No. 173886)
Jon T. King (Bar No. 205073)
HAGENS BERMAN SOBOL SHAPIRO LLP
715 Hearst Avenue, Suite 202
Berkeley, CA 94710
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Robert Carey
HAGENS BERMAN SOBOL SHAPIRO LLP
11 W Jefferson St,
Phoenix, AZ 85003
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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DATED: January 7, 2015

PEARSON, SIMON & WARSHAW, LLP

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By: /s/ Bruce L. Simon
BRUCE L. SIMON
Aaron M. Sheanin (Bar No. 214472)
Benjamin E. Shiftan (Bar No. 265767)
44 Montgomery Street, Suite 2450
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

1
Plaintiffs’ Interim Co-Lead Class Counsel

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DATED: January 7, 2015

WINSTON & STRAWN LLP

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By: /s/ Jeffrey L. Kessler
JEFFREY L. KESSLER

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David Feher
David Greenspan
200 Park Avenue
New York, NY 10166
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

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SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Attorneys for the Jenkins Plaintiffs,
Plaintiffs’ Interim Co-Lead Class Counsel

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DATED: January 7, 2015

PROSKAUER ROSE LLP

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By: /s/ Scott P. Cooper
SCOTT P. COOPER

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Jennifer L. Jones (Bar No. 284624)
Sarah Kroll-Rosenbaum (Bar No. 272358)
Jacquelyn N. Ferry (Bar No. 287798)
2049 Century Park East, Suite 3200
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant Pac-12 Conference
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DATED: January 7, 2015

MAYER BROWN LLP

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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By: /s/ Andrew S. Rosenman
ANDREW S. ROSENMAN

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Andrew S. Rosenman (Bar No. 253764)
Britt M. Miller (pro hac vice)
71 South Wacker Drive
Chicago, IL 60606-4637
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Richard J. Favretto (pro hac vice)
MAYER BROWN LLP
1999 K Street, N.W.
Washington, D.C. 20006-1101
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Attorneys for Defendant The Big Ten Conference, Inc.

15 DATED: January 7, 2015

ROBINSON BRADSHAW & HINSON

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By: /s/ Robert W. Fuller
ROBERT W. FULLER

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Nathan C. Chase, Jr. (Bar No. 247526)
Robert W. Fuller, III (pro hac vice)
Mark W. Merritt (pro hac vice)
Lawrence C. Moore, III (pro hac vice)
Amanda R. Pickens (pro hac vice)
101 N. Tryon St., Suite 1900
Charlotte, NC 28246
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Mark J. Seifert (Bar No. 217054)
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

Robert R. Moore (Bar No. 113818)
ALLEN MATKINS LECK GAMBLE MALLORY &
NATSIS LLP
Three Embarcadero Center, 12th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Defendant Southeastern Conference

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8 DATED: January 7, 2015

SMITH MOORE LEATHERWOOD LLP

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By: /s/ D. Erik Albright
D. ERIK ALBRIGHT

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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D. Erik Albright (pro hac vice)
300 North Greene Street, Suite 1400
Greensboro, NC 27401
Telephone: [phone]
Facsimile: [phone]
Email:[e-mail]

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Jonathan P. Heyl (pro hac vice)
101 N. Tryon Street, Suite 1300
Charlotte, NC 28246
Telephone: [phone]
Facsimile: [phone]
Email:[e-mail]

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Charles LaGrange Coleman, III (SBN 65496)
HOLLAND & KNIGHT LLP
50 California Street, Suite 2800
San Francisco, CA 94111-4624
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Atlantic Coast Conference

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DATED: January 7, 2015

POLSINELLI PC

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By: /s/ Leane K. Capps
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

LEANE K. CAPPS

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Leane K. Capps (pro hac vice)
POLSINELLI PC
Saint Ann Court
2501 N. Harwood Street, Suite 1900
Dallas, TX 75201
Telephone: [phone]
Email: [e-mail]

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Amy D. Fitts (pro hac vice)
POLSINELLI PC
120 W. 12th Street
Kansas City, MO 64105
Telephone: [phone]
Email: [e-mail]

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SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Wesley D. Hurst (SBN 127564)
POLSINELLI LLP
2049 Century Park East, Suite 2300
Los Angeles, CA 90067
Telephone: [phone]
Email: [e-mail]

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Attorneys for Defendant The Big 12 Conference, Inc. and
Conference USA

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DATED: January 7, 2015
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SKADDEN ARPS SLATE MEAGHER & FLOM
LLP

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By: /s/ Karen Hoffman Lent
KAREN HOFFMAN LENT
Raoul D. Kennedy (Bar No. 40892)
525 University Avenue, Suite 1100
Palo Alto, California 94301
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Jeffrey Mishkin (pro hac vice)
Karen Hoffman Lent (pro hac vice)
Four Times Square
New York, NY 10036
Telephone: [phone]
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

Facsimile [phone]
Email: [e-mail]
Email: [e-mail]

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Robert J. Wierenga (Bar No.183687)
Gregory L. Curtner (pro hac vice)
Kimberly K. Kefalas (pro hac vice)
Jacob K. Danziger (SBN 278219)
SCHIFF HARDIN LLP
350 S. Main St., Suite 210
Ann Arbor, MI 48104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Attorneys for Defendant National Collegiate Athletic
Association

13 DATED: January 7, 2015

COVINGTON & BURLING LLP

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By: /s/ Benjamin C. Block
BENJAMIN C. BLOCK

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Benjamin C. Block (pro hac vice)
One CityCenter
850 Tenth Street, N.W.
Washington, DC 20001-4956
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Matthew D. Kellogg (Bar No. 280541)
One Front Street
San Francisco, CA 94111-5356
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for American Athletic Conference
DATED: January 7, 2015

JONES WALKER LLP

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

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By: /s/ Mark A. Cunningham
MARK A. CUNNINGHAM

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Mark A. Cunningham (pro hac vice)
201 St. Charles Avenue
New Orleans, LA 70170-5100
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Sun Belt Conference

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DATED: January 7, 2015

WALTER | HAVERFIELD LLP

SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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By: /s/ R. Todd Hunt
R. TODD HUNT

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R. Todd Hunt (pro hac vice)
The Tower at Erieview
1301 E. 9th Street, Suite 3500
Cleveland, OH 44114-1821
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Mid-American Conference
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19 DATED: January 7, 2015

BRYAN CAVE LLP

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By: /s/ Adam Brezine
ADAM BREZINE
Adam Brezine (Bar No. 220852)
560 Mission Street, 25th Floor
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Richard Young (pro hac vice application to be filed)
14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES

Brent Rychener (pro hac vice application to be filed)
90 South Cascade Avenue, Suite 1300
Colorado Springs, CO 80903
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Defendant Mountain West Conference

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DATED: January 7, 2015

BRADLEY DEVITT HAAS & WATKINS, P.C.

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By: /s/ Jon T. Bradley
JON T. BRADLEY

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SAN FRANCISCO, CALIFORNIA 94104

PEARSON, SIMON & WARSHAW, LLP

44 MONTGOMERY STREET, SUITE 2450

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Jon T. Bradley (pro hac vice application to be filed)
2201 Ford Street
Golden, CO 80401
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Western Athletic Conference

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16 PURSUANT TO STIPULATION,
IT IS SO ORDERED.
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18 DATED: January ___, 2015
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THE HON. CLAUDIA WILKEN
UNITED STATES DISTRICT JUDGE

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14-md-2541-CW; 4:14-cv-02758-CW
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STIPULATED [PROPOSED] ORDER REGARDING PRODUCTION OF DOCUMENTS FROM CERTAIN
OTHER CASES