Nike USA, Inc. v. Berian

Filing 15

Declaration of Merhawi Keflezighi in Support of Defendant's Opposition to Nike's Motion to Expedite. Filed by Boris Berian. (Related document(s): Response in Opposition to Motion 14 .) (Ferranti, William)

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Case 3:16-cv-00743-SB Document 15 Filed 06/05/16 Page 1 of 2 William P. Ferranti. OSB # 160069 wpf::ij) THE FERRANTI FIRM LLC 1819 SW 5th Ave. #403 Portland. Oregon 97201 Tel: (503) 877-9220 Vincent C. £\\fog. admitted pro hac vice vce,ving@) LAW OFFICE OF VINCENT C. EWING 111 West Ocean Blvd .. Suite 400. PMB 444 Long Beach. C ,\ 90802 Tel: 626-818-5245 A rforneysfhr Dc/i:ndcmt Boris Berian UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION NTKE USA. INC.. an Oregon corporation. Case No. 3: 16--cv- 00743-SB Plaintiff. V. BORJS BERT!\N. an individual California resident, Defendant. llECLARA TlON OF MERHA WI KEFLEZlGHI In Support Of Defendant Boris Berian's Opposition To Nike's Motion For Expedited Preliminary Injunction Hearing and Related Discff\:ery Case 3:16-cv-00743-SB Document 15 Filed 06/05/16 Page 2 of 2 L Merhawi Keflezighi. hereby declare as follows: 1. I am the Founder and Director of HA WI Management. l submit this declaration in support of Defendant Boris Berian · s Opposition To Nike· s Motion For Expedited Preliminary Injunction Hearing and Related Discovery The information herein is based on my personal knovvledge. and. if called and sworn as a \Vitness. J could and would testify competently thereto . ' I have been Boris Berian·s agent since October l. 2015. On February 15. 2016. Nike sent to me by email a document that it has characterized as a 2016 Contract betv,een Nike and Mr. Berian. 4. That document included. among numerous other terms and provisions. the foll owing .. AFFIUA TION .. clause. as paragraph VII of ··SCHEDtJLE A BORIS BE RIAN COMPENSATION AND BONUS SCHEDULE .. : NIKE shall permit ATHLETE to compete under the Big Bear Track Club affiliation. and ATHLETE may wear the official uniform and footwear of Big Bear Track Club in all domestic competitions. including the US Indoor Championships and US Olympic Trials. in 2016. ATHLETE shall compete for Team NIKE and \Vear the Team NIKE official uniform in all international eYents. 5. I anticipate authenticating and submitting the entirety of this document for the Coun·s review after Ivlr. Berian·s counsel has an opportunity to address with Nike·s counsel the need (if an)) for the document to be redacted or filed under seal. I declare under penalty of pe1jury that the foregoing is true and correct. Executed on June 5. 2016. TVfERHA WI KEFLEZIGHI FOUNDER AND DIRECTOR l-lAWI MANAGEIVfENT

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