BOYD et al v. NATIONAL FOOTBALL LEAGUE et al

Filing 1

COMPLAINT against NATIONAL FOOTBALL LEAGUE, NFL PROPERTIES LLC ( Filing fee $ 350 receipt number 055871.), filed by MACARTHUR LANE, MARK COOPER, BRAD JACKSON, ROBERT BELL, CHARLES ANTHONY, CLIFF HARRIS, MARVIN WOODSON, PAUL KRAUSE, NOEL JENKE, CHARLES MYRTLE, CEDRICK HARDMAN, BRUCE LAIRD, JOE DELAMIELLEURE, DON HORN, DENNIS HARRAH, JAMES WILLIAMS, MARK KONAR, TOMMY NOBIS, JAMES JONES, CALVIN JACKSON, TROY JOHNSON, MICHAEL MORTON, PETER LAZETICH, CALEB MILLER, JOSEPH KAPP, MICHAEL WEDDINGTON, HARVEY ARMSTRONG, DERLAND MOORE, MICHAEL MERRIWEATHER, JAMES HARRELL, AARON JONES, II, KENNETH EASLEY, JR, ESTATE OF GREGORY LENS, RICK SANFORD, WILLIAM "BILLY&quo SHIELDS, GARY PADJEN, CHARLES KRUEGER, PHIL VILLAPIANO, KEN FANTETTI, DONNIE GREEN, LEON "RAY" JARVIS, EDWARD WHITE, JOE FERGUSON, JR, LARRY WOODS, DONALD MACEK, JEFF BARNES, CHARLIE SMITH, LEE FOLKINS, DERRICK GAFFNEY, AUGUST "GUS" OTTO, PHILLIP FREEMAN, III, OLRICK JOHNSON, JR, WILLIE GREEN, JAMES HOUGH, CHARLEY HARRAWAY, THOMAS BEER, JAMES GARCIA, FRED FORSBERG, TERRANCE "TERRY&quo METCALF, BOBBY HARDEN, JR, DENNIS MCKNIGHT, ALFRED GROSS, GENE LANG, LEMUEL BARNEY, BRENT BOYD, DELLES HOWELL, JERRY ROBINSON, WILLIAM "BILL" CODY, VICTOR HICKS, ARTHUR STILL, REGINALD CLARK, CRAIG CURRY, DONALD MANOUKIAN, MARK NICHOLS, JEFF MCINTYRE, DAVID RECHER, LEONARD "BUBBA&quo MCDOWELL, JR, MIKE WOOD, TERRY OWENS, CLARENCE VERDIN, BRYAN STOLENBERG, ROD MARTIN, ROBERT KROLL, KEITH NORD, MICHAEL "TONY" DAVIS, CONRAD DOBLER, MELVIN CARVER, MIKE AUGUSTYNIAK, TRUMAINE JOHNSON, FRED SMERLAS, RANDY RAGON, MARGENE ADKINS, NEAL CRAIG, WILLIAM "BILLY&quo TRUAX, KORY MINOR, J. BRUCE JARVIS, LIONEL ANTOINE, STEVE JONES, PETER CRONAN, IRA MATTHEWS, III, MARK COTNEY, JEFFREY WALKER, MERVIN KRAKAU, JON MELANDER, LARRY WEBSTER, FRED ANDERSON. (Attachments: # 1 complaint, # 2 complaint, # 3 complaint, # 4 complaint, # 5 complaint, # 6 complaint, # 7 complaint, # 8 complaint, # 9 complaint, # 10 complaint, # 11 complaint, # 12 complaint, # 13 complaint, # 14 complaint, # 15 complaint, # 16 complaint, # 17 complaint, # 18 complaint, # 19 Civil Cover Sheet)(mima, )

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dizziness, loss of memory, impulse control problems, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck/cervical spine arthritis and associated numbness and tingling. 12. Plaintiff Jeff Barnes ("Bames") is 56 years old and resides with his wife in Stockton, Califomia. He was an NFL linebacker who played for the Oakland/Los Angeles Raiders (1977-87). Barnes was a member of the Raiders' Super Bowl XV and XVIII Championship teams. Barnes suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Barnes has experienced cognitive difhculties including, but not limited to headaches, dizziness, loss of memory, impulse control problems, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck/cervical spine arthritis and associated numbness and tingling. 13. Plaintiff Lemuel Barney ("Barney") is 66 years old and resides with his wife in Michigan. He was an NFL defensive back who played with the Detroit Lions (1967-77). He was voted NFL Defensive Rookie of the Year in 1967 and was selected to the NFL's 1960s All Decade Team. He was a seven-time Pro Bowl selection (1967-69,1972-73,1975-76) and was a seven-time All Pro selection (1967-70,1972-73,1975). He was elected to the Pro Football HallofFamein1992. Inl999,BarneywasincludedintheSportingNews'slistofthe 100 greatest football players. Barney suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Barney has experienced cognitive difficulties including, but not limited to headaches, dizziness, initability, sleep problems, neck and cervical arthritis and associated numbness/tingling. 14. Plaintiff Thomas Beer (ooBeer") is 67 years old and resides in Pine Brook, New Jersey. He was an NFL tight end who played for the Denver Broncos (1967-68), and the BostonAtrew England Patriots (197I-72). Beer suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Beer has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, depression, and neck and cervical arthritis. 15. Plaintiff Robert Bell ("Bell") is 63 years old and resides with his wife in North Wales, Pennsylvania. He was an NFL defensive tackle for the Detroit Lions (1971-73), and the St. Louis Cardinals (1974-78). Bell suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Bell has experienced cognitive difficulties including, but not limited to headaches, dizziness, and loss of memory. 16. wife in Plaintiff Melvin Carver ("Carver") is 52 years old and resides with his T*pu, Florida. He was an NFL running back for the Tampa Bay Buccaneers and the Indianapolis Colts career in the (1982-85), (1987). Carver suffered repeated and chronic head impacts during his NFL and is at an increased risk of latent brain disease. As a result, Carver has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck/cervical spine arthritis and associated numbness and tingling. 17. Plaintiff Reginald Clark ("Clark") is 44 years old and resides with his wife in North Carolina. He was an NFL linebacker who played for the Pittsburgh Steelers (1994), and the Jacksonville Jaguars (1995-96). Clark suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Clark has experienced cognitive difficulties including, but not limited to headaches, dizziness, blurry vision, ringing in ears, loss of memory, impulse control problems, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck and cervical arthritis and associated numbness/tingling. 18. Plaintiff William'oBill" Cody ("Cody") is 67 years old and resides in Fairhope, Alabama. He was an NFL linebacker who played for the Detroit Lions (1966), the New Orleans Saints (1967-70), and the Philadelphia Eagles (1972). Cody suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Cody has experienced cognitive difficulties. 19. Plaintiff Mark Cooper ("Cooper") is 5l years old and resides in Aurora, Colorado. He was an NFL offensive tackle who played for the Denver Broncos (1983-87), and the Tampa Bay Buccaneers (1987-89). Cooper suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Cooper has experienced cognitive difficulties including, but not limited to sleep problems, and neck and cervical numbness/tingling. 20. Plaintiff Mark Cotney ("Cotney") is 59 years old and resides with his wife inLutz, Florida. He was an NFL defensive back who played for the Houston Oilers (1975), and the Tampa Bay Buccaneers (1976-84). Cotney was selected by the Tampa Bay Buccaneers in the 1976 Expansion Draft and was a member of the original winless lgT6Buccaneers team. Cotney suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Cotney has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, depression, fatigue, sleep problems, irritability, neck and cervical arthritis and associated numbness/tingling. 21. Plaintiff Neal Craig ("Craig") is 63 years old and resides in Ohio. He was an NFL defensive back for the Cincinnati Bengals (1971-73), the Buffalo Bills (1974), and the Cleveland Browns (1975-76). Craig suffered repeated and chonic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Craig has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, fatigue, and numbness/tingling in neck and cervical spine. 22. Plaintiff Peter Cronan (o'Cronan") is 56 years old. He was an NFL linebacker for the Seattle Seahawks (1977-81), and the Washington Redskins (19S1-S5). Cronan was a member of the Washington Redskins Super Bowl XVII Championship team. Cronan suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Cronan has experienced cognitive diffrculties including, but not limited to headaches, lightheadedness, and dizziness. 23. Plaintiff Craig Curry ("Curry') is 50 years old and resides in Houston, Texas. He was an NFL defensive back for the Tampa Bay Buccaneers (1984-86), and the Indianapolis Colts (1987). Curry suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Curry has experienced cognitive difficulties. 24. Plaintiff Michael "Tony" Davis ("Davis") is 58 years old and resides in Greeley, Colorado. He was an NFL running back for the Cincinnati Bengals (1976-78), and the Tampa Bay Buccaneers (1979-81). In 1977,Davis was voted team MVP by the Bengals. Davis suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Davis has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, fatigue, sleep problems, irritability, neck and cervical arthritis and associated numbness/tingling. 25. Plaintiff Joseph Delamielleure ("Delamielleure") is 60 years old and resides with his wife in Charlotte, North Carolina. He was an NFL offensive guard who played for the Buffalo Bills (1973 -79,1985) and the Cleveland Browns (19S0-S4). He was selected to be included in the Wall of Fame for both teams. He was voted Co-Offensive Lineman of the Year in 1973 and the NFLPA/AFC Offensive Lineman of the Year in 1975. In l977,he received the Forrest Gregg Award as the NFL Offensive Lineman of the Year. He was selected six times to the Pro Bowl (1975-80) and as All Pro (1975-80). Delamielleure was elected to the Pro Football Hall of Fame in 2003. Delamielleure suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Delamielleure has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, depression, suicidal thoughts, fatigue, sleep problems, irritability, 600/ohearing loss in left eat, neck and cervical spine arthritis and associated numbness/tingling. 26. Plaintiff Conrad Dobler ("Dobler") is 61 years old and resides in Overland Park, Kansas. He was an NFL offensive guard for the St. Louis Cardinals (1972-77),New Orleans Saints (1978-79), and Buffalo Bills (1980-81). He was a six-time Pro Bowl selection (I975-77). Dobler is90% disabled today, having had nine knee replacement surgeries alone. Dobler suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of latent brain disease. As a result, Dobler has experienced cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, dementia, impulse control problems, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck and cervical arthritis and associated numbness/tingling. 27. Plaintiff Kenneth Easley, Jr. ("Easley") is 52 years old and resides in Norfolk, Virginia. He was an NFL defensive back who played for the Seattle Seahawks (1931- 87). He was a five-time Pro Bowl selection, four-time All-Pro, was the 1984 NFL Defensive Player of the Year, and a member of the NFL's 1980s All-Decade Team. Easley suffered repeated and chronic head impacts during his career in the NFL and is at an increased risk of

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