Brady et al v. National Football League et al

Filing 142

DOCUMENT FILED IN ERROR, CAPTION INCORRECT, WILL RE-FILE. MOTION to Alter/Amend/Supplement Pleadings Leave to Amend and Crossclaim by Obafemi Ayanbadejo, Ryan Collins, Carl Eller. (Attachments: # 1 Second Amended Complaint, # 2 Exhibit(s) Index, # 3 Exhibit(s) A, # 4 Exhibit(s) B, # 5 Exhibit(s) C, # 6 Exhibit(s) D, # 7 Exhibit(s) E, # 8 Exhibit(s) F, # 9 Exhibit(s) G, # 10 Exhibit(s) H, # 11 Exhibit(s) I, # 12 Exhibit(s) J, # 13 Exhibit(s) K, # 14 Exhibit(s) L, # 15 Exhibit(s) M, # 16 Exhibit(s) N, # 17 Exhibit(s) O, # 18 Exhibit(s) P, # 19 Exhibit(s) Q, # 20 Exhibit(s) R, # 21 Exhibit(s) S, # 22 Exhibit(s) T, # 23 Exhibit(s) U, # 24 Exhibit(s) V, # 25 Exhibit(s) W, # 26 Exhibit(s) X)(Stuckey, Shawn) Modified on 7/7/2011 (JME).

EXHIBIT INDEX
A

White v. NFL, No. 4-92-906 (DSD), 2011 WL 706319 (D. Minn. March 1,
2011) (“the White case”)

B

Internal NFL document entitled “Decision Tree” made publicly available in
the White case

C

Internal NFL document entitled “Key Current NFL Media Objectives” made
publicly available in the White case

D

Internal NFL document entitled “Current Television Packages Short Term
Extension Alternative” made publicly available in the White case

E

Internal NFL document entitled “Short Term Extension: Concept
Overview” made publicly available in the White case

F

Letter dated August 6, 2009, from the NFL Players Association (“NFLPA”)
to the National Football League (“NFL”) made publicly available at its
website NFLLockout.com

G

Letter dated June 7, 2010, from the NFLPA to the NFL made publicly
available at its website NFLLockout.com

H

Letter dated July 8, 2010, from the NFLPA to the NFL made publicly
available at its website NFLLockout.com

I

Letter dated October 27, 2010, from the NFLPA to the NFL made publicly
available at its website NFLLockout.com

J

Letter dated December 15, 2010, from the NFLPA to the National Football
League Management Council made publicly available at its website
NFLLockout.com

K

Letter dated May 18, 2010, from the NFLPA to the NFL made publicly
available at its website NFLLockout.com

L

Memorandum dated March 11, 2011, from the NFLPA to the NFL Club
Presidents and General Managers made publicly available at its website
NFLLockout.com

M

Letter dated March 11, 2011, from the NFLPA to the NFL made publicly
available at its website NFLLockout.com

N

Letter dated March 11, 2011, from the NFL to the NFLPA made publicly
available at the NFLPA’s website NFLLockout.com

O

Press release issued by the Federal Mediation & Conciliation Service dated
March 11, 2011 that is publicly available from its website

P

“Bert Bell/Pete Rozelle NFL Player Retirement Plan” that is publicly
available from its website

Q

April 8, 2008, report issued by the Congressional Research Service (“CRS”)
on “Former NFL Players: Disabilities, Benefits And Related Issues.”

R

August of 2010, letter sent by United States Department of Labor (“DoL”)
putting the Plan on "endangered" status because the Plan's funded
percentage was only 75% that is publicly available from its website

S

A copy of the last iteration of the 88 Plan that is publicly available from its
website

T

Adderley v. National Football League Players, Inc., No. 3:07-cv-00943WHA (N.D. Cal.) (Order denying post-trial motions)

U

Grant v. NFLPA, No. 2:11-cv-00318-RGK-FFM (C.D. Cal. June 6, 2011)
(1st Amended Complaint)

V

March 17, 2011, letter from Roger Goodell to active NFL players that is
publicly available

W

April 4, 2011, letter from Mark Murphy (President and CEO of the Green
Bay Packers) and Jerry Richardson (owner of the Carolina Panthers) to
former NFL players that is publicly available
Email from counsel for the Brady plaintiffs to counsel for the Eller plaintiffs

X

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