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).

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From:                              Quinn, James [[e-mail]]
Sent:                               Thursday, May 19, 2011 10:45 AM
To:                                   [e-mail]; Michael Hausfeld
Subject:                          RE: Homework
I spoke to Pash who seemed generally OK with our proposal. As I understand it, Jeff will coordinate directly with 
Michael on the retiree issues.

James W. Quinn

Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
[e-mail]
[phone]
Direct
[phone]

Mobile

[phone]

Secondary Mobile

[phone]

Fax

From: Kessler, Jeffrey [mailto:[e-mail]]
Sent: Thursday, May 19, 2011 12:15 PM
To: Michael Hausfeld
Cc: Quinn, James
Subject: RE: Homework
We put in a call to Pash to try to find a time to do this. Our thinking is very simple. We would propose that the
Brady plaintiffs cover the economic system issues: free agency rules and restrictions, rookie rules and
restrictions; and the economic split ( i.e., salary cap or no salary cap, revenue split with players, etc). Eller would
make the proposal on the retired player issues. We do not want to cover anything that would only be in a CBA,
such as the drug program, etc. We will let you know when we hear from Pash.
-----------------------------------------------------------Jeffrey L. Kessler
Partner -- Global Litigation Department Chair
Dewey & LeBoeuf LLP
1301 Avenue of the Americas
New York, NY 10019
Direct: [phone]
General: [phone]
Fax: [phone]
[e-mail]

From: Michael Hausfeld [mailto:[e-mail]]
Sent: Thursday, May 19, 2011 12:04 PM
To: Kessler, Jeffrey; [e-mail]
Cc: [e-mail]; [e-mail]
Subject: RE: Homework

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When can we schedule a call to discuss the Judge’s direction?

Best wishes, Michael

Michael D. Hausfeld, Chairman
[e-mail]
202.540.7200 ph

1700 K Street, NW, Suite 650, Washington, DC 20006
202.540.7200 main / 202.540.7201 fax / www.hausfeldllp.com
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From: Kessler, Jeffrey [mailto:[e-mail]]
Sent: Wednesday, May 18, 2011 7:57 PM
To: [e-mail]; Michael Hausfeld; [e-mail]
Cc: [e-mail]; [e-mail]
Subject: Re: Homework

Thank you. We will do so.

Jeffrey L. Kessler
Partner --Global Litigation Chair
Dewey & LeBoeuf LLP
1301 Avenue of the Americas
New York, New York 10019
(T) 212-259-8050
(F) 212-259-6333
----- Original Message ----From: [e-mail] <[e-mail]>
To: Kessler, Jeffrey; Michael Hausfeld <[e-mail]>; [e-mail] <[e-mail]>
Sent: Wed May 18 14:48:36 2011
Subject: Homework
Gentlemen:
Before emailing the parties submissions due on Friday, May 27, please meet
and confer with a view to agreeing on the list of the "points of
discussion" that will be commented on. Also agree on the order in which
each point will appear on the submissions.
Thank you.

Arthur J. Boylan

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