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 [james.quinn@weil.com]
Sent: Thursday, May 19, 2011 10:45 AM
To: jkessler@DeweyLeBoeuf.com; 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
james.quinn@weil.com
+1 212 310 8385
Direct
+1 646 465-3604
Mobile
+1 914 645-4892
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+1 212 735-4657
Fax
From: Kessler, Jeffrey [mailto:jkessler@DeweyLeBoeuf.com]
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: +1 212 259 8050
General: +1 212 259 8000
Fax: +1 212 259 6333
Jkessler@dl.com
From: Michael Hausfeld [mailto:mhausfeld@hausfeldllp.com]
Sent: Thursday, May 19, 2011 12:04 PM
To: Kessler, Jeffrey; jeffrey.pash@nfl.com
Cc: James.quinn@weil.com; glevy@cov.com
Subject: RE: Homework
file://C:\Documents and Settings\eray\Local Settings\Temporary Internet Files\OLK169\RE ... 7/4/2011
Page 2 of 4
When can we schedule a call to discuss the Judge’s direction?
Best wishes, Michael
Michael D. Hausfeld, Chairman
mhausfeld@hausfeldllp.com
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:jkessler@DeweyLeBoeuf.com]
Sent: Wednesday, May 18, 2011 7:57 PM
To: ajboylan@mnd.uscourts.gov; Michael Hausfeld; jeffrey.pash@nfl.com
Cc: James.quinn@weil.com; glevy@cov.com
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: ajboylan@mnd.uscourts.gov
To: Kessler, Jeffrey; Michael Hausfeld ; jeffrey.pash@nfl.com
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
file://C:\Documents and Settings\eray\Local Settings\Temporary Internet Files\OLK169\RE ... 7/4/2011
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Dewey & LeBoeuf LLP in London and Paris is a limited liability partnership
registered in England and Wales under number OC355432 with its registered
office at 1 Minster Court, Mincing Lane, London EC3R 7YL and is a law firm
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