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, )
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