NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION v. SAGAPOLUTELE et al

Filing 5

Memorandum in opposition to re 1 MOTION to Quash filed by PIO SAGAPOLUTELE, SEAN LAMAR SMITH, BRUCE SCHWAGER. (Smith, Cyril)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, Movant * v. PIO SAGAPOLUTELE, et al., Respondents. * * * * * * * Case No. 1:08-mc-00653-RMU * (pending in the District of Maryland as Case No. 08-01870 WMN) * * * * * * * * * * *

RESPONDENTS' OPPOSITION TO MOVANT'S MOTION TO QUASH Respondents Pio Sagapolutele, Sean Lamar Smith, and Bruce Schwager, oppose the Motion to Quash filed by movant, the National Football League Players Association ("NFLPA"). Respondents incorporate by reference their combined

Memorandum in support of (1) this Opposition to the Motion to Quash filed by the NFLPA; and (2) Respondents' Motion to Compel Production of Documents. Dated: October 22, 2008 /s/ Cyril V. Smith D.C. Bar No. 413941 William K. Meyer Motion for Admission Pro Hac Vice Pending Zuckerman Spaeder LLP 100 East Pratt Street, Suite 2440 Baltimore, MD 21202 [phone] Attorneys for Respondents

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22nd day of October 2008, a copy of the foregoing Opposition to Movant's Motion to Quash and supporting Memorandum and exhibits were served by email and first class mail, postage prepaid, upon the following:

Joseph A. Yablonski Joseph A. Yablonski, P.L.L.C. 1776 K Street, N.W. Suite 840 Washington, DC 20006

Hisham M. Amin Groom Law Group, Chartered 1701 Pennsylvania Avenue, N.W. Suite 1200 Washington, DC 20006

/s/ Cyril V. Smith

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