Brady et al v. National Football League et al

Filing 76

DECLARATION of Daniel J. Connolly in Opposition (originally filed in 11-748 SRN/JJG on 4/4/11) to 58 MOTION for Preliminary Injunction filed by Arizona Cardinals, Inc., Atlanta Falcons Football Club LLC, Baltimore Ravens Limited Partnership, Buccaneers Limited Partnership, Buffalo Bills, Inc., Chicago Bears Football Club, Inc., Cinncinnati Bengals, Inc., Cleveland Browns LLC, Dallas Cowboys Football Club, Ltd., Denver Broncos Football Club, Detroit Lions, Inc., Football Northwest LLC, Green Bay Packers, Inc., Houston NFL Holdings LP, Indianapolis Colts, Inc., Jacksonville Jaguars Ltd., Kansas City Chiefs Football Club, Inc., Miami Dolphins, Ltd., Minnesota Vikings Football Club LLC, National Football League, New England Patriots, LP, New Orleans Louisiana Saints, LLC, New York Football Giants, Inc., New York Jets Football Club, Inc., Oakland Raiders LP, Panthers Football LLC, Philadelphia Eagles Football Club, Inc., Pittsburgh Steelers Sports, Inc., Rams Football Co, LLC, The, San Diego Chargers Football Co., San Francisco Forty Niners Ltd., Tennessee Football, Inc., Washington Football Inc. (Attachments: # 1 Exhibit A)(akl)

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
CARL ELLER, et al.,
Plaintiffs,
v.
NATIONAL FOOTBALL LEAGUE, et al.,
Defendants.

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) No. 0:11-cv-00748-SRN-JJG
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Declaration of Daniel J. Connolly
I, Daniel J. Connolly, hereby declare as follows:
1.

I am a partner at the law firm of Faegre & Benson in

Minneapolis, Minnesota, which represents Defendants National Football
League et al. in this matter. I have personal knowledge of and am competent
to testify to the following:
2.

Exhibit A hereto is a true and correct copy of the NFLPA

publication The Huddle, published before the Union’s purported disclaimer.
At page 5 it indicates that the NFLPA members “gave the NFLPA permission
to renounce its union status in the event of a lockout.” See Exhibit A, at 5.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 4, 2011.

s/Daniel J. Connolly
Daniel J. Connolly, #197427

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