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, )

latent brain disease. As a result, Easley has experienced cognitive difficulties including, but not

limited to dizziness, loss of memory, sleep problems, and numbness/tingling in neck and cervical
spine.

28.

Plaintiff Ken Fantetti ("Fantetti") is 54 years old. He was an NFL

linebacker who played for the Detroit Lions (1979-85). Fantetti 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, Fantetti 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.
29

.

Plaintiff Lee Folkins ("Folkins") is 72

years old and resides

with his wife

in Orlando, Florida. He was an NFL tight end who played for the Green Bay Packer (1961), the
Dallas Cowboys (1962-64), and the Pittsburgh Steelers (1965). He was selected to play in the
1963 Pro

Bowl. Folkins 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, Folkins has experienced
cognitive difficulties including, but not limited to headaches, dizziness, loss of memory,

initability,

and neck and cervical spine numbness/tingling.

30.

Plaintiff Fred Forsberg ("Forsberg") is 67 years old and resides in

Sammamish, Washington. He was an NFL linebacker who played for the Denver Broncos
(1968-73), the Buffalo Bills (1973), and the San Diego Chargers (1974). Forsberg 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, Forsberg has experienced cognitive difficulties including, but
not limited to headaches, dizziness, loss of memory, neck and cervical arthritis and associated
numbness/tingling.

31.

Plaintiff Phillip Freeman, III (ooFreeman") is 49 years old and resides in

Tampa, Florida. He was an NFL wide receiver and kick retumer for the Tampa Bay Buccaneers

(1985-87). Freeman 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, Freeman has experienced cognitive

difficulties including, but not limited to headaches, dizziness, loss of memory.

32.

Plaintiff Joe Ferguson, Jr. (ooFerguson") is 6l years old and resides in Bella

Vista, Arizona. He was an NFL quarterback for the Buffalo Bills (1973-1984), the Tampa Bay
Buccaneers (1988-89), and the Indianapolis Colts (1990).

In 1993, Ferguson was inducted into

the Buffalo Bills Wall of Fame and his number 12 Jersey was retired in honor of both Ferguson
and fellow quarterback Jim

Kelly. Ferguson 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, Ferguson has
experienced cognitive difficulties including, but not limited to headaches, dizziness, loss

of

memory, and initability.

33.

Plaintiff Derrick Gaffney ("Gaffirey") is 56 years old and resides in

Jacksonville, Florida. He was an NFL wide receiver for the New York Jets (1978-87). Gaffney
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, Gaffney has experienced cognitive diffrculties including,
but not limited to headaches, dizziness, loss of memory, impulse control problems, neurological
disorder, depression, suicidal thoughts, fatigue, sleep problems, irritability, neck and cervical

arthritis and associated numbness/tingling, blurred vision, and ringing in ears.

34.

Plaintiff James Garcia ("Garcia") is 67 years old and resides in San

Antonio, Texas. He was an NFL defensive end who played for the Cleveland Browns (1965),
the New

York Giants (1966), the New Orleans Saints (1967), and the Atlanta Falcons (1963).

l0

Garcia 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, Garcia has experienced cognitive difficulties.

35.

Plaintiff Donnie Green ("D. Green") is 63 years old and resides in

Hagerstown, Maryland. He was an NFL tackle who played for the Buffalo Bills (1971-76),the

Philadelphia(1977), and the Detroit Lions (1978). D. Green 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, D. Green has experienced cognitive difficulties including, but not limited to headaches,
dizziness, loss of memory, fatigue, sleep problems, and numbness/tingling in neck and cervical
spine.

36.

Plaintiff Willie Green (ooGreen") is 45 years old and resides with his wife

in North Carolina. He was an NFL wide receiver who played for the Detroit Lions (1991-93),
the Tampa Bay Buccaneers (1994), the Carolina Panthers (1995-96), and the Denver Broncos

(1997-98). Green 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, Green has experienced cognitive

difficulties including, but not limited to headaches, loss of memory, depression, and sleep
problems.

37.

Plaintiff Alfred Gross ("Gross") is 50 years old and resides in Phoenix,

Arizona. He was an NFL defensive back for the Cleveland Browns (1983-87). Gross 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, Gross has experienced cognitive difficulties including, but not

limited to headaches, loss of memory, impulse control problems, neurological disorder,
depression, suicidal thoughts, fatigue, sleep problems, irritability, neck and cervical arthritis and
associated numbness/tingling.

11

38.

Plaintiff Bobby Harden, Jr. ("Harden") is 44 years old and resides in

Lauderhill, Florida. He was an NFL defensive back who played for the Miami Dolphins (1990-

93). Harden 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, Harden has experienced cognitive

difficulties including, but not limited to dizziness,loss of memory, and initability.

39.

Plaintiff Cedrick Hardman ("Hardman") is 63 years old and resides in

Laguna Beach, California. He was an NFL defensive end who played for the San Francisco
49ers (1970-79), and the Oakland Raiders (1980-81). He is the current all-time sack leader for

the San Francisco 49ers franchise, and was a two-time Pro Bowl selection in

I97l

and 1975.

Hardman was a member of the Raiders' Super Bowl XV Championship team. Hardman 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, Hardman has experienced cognitive diffrculties including, but

not limited to loss of memory, neck and cervical arthritis and associated numbness/tingling.

40.

Plaintiff Dennis Harrah ("Harrah") is 58 years old and resides in

Charleston, West Virginia. He was an NFL offensive guard for the Los Angeles Rams (1975-

87). He was a six-time Pro Bowl selection (1978-80, 1985-87), and was voted All-Pro (1986).
Harrah 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, Harrah has experienced cognitive difficulties.

41.

Plaintiff Charley Harraway ("Harraway") is 67 years old and resides with

his wife in Sarasota, Florida. He was an NFL running back who played for the Cleveland

Browns (1966-68), and the Washington Redskins (1969-73). In 1966, Harraway was selected by
teams in both the

AFL

and

NFL drafts. Harraway 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,

t2

Harraway has experienced cognitive difficulties including, but not limited to headaches,
dizziness, loss of memory, impulse control problems, suicidal thoughts, fatigue, sleep problems,

irritability, neck and cervical arthritis and associated numbness/tingling.

42.

Plaintiff James Harrell ("Harrell") is 54 years old and resides in Florida.

He was an NFL linebacker for the Detroit Lions (1979-86), and the Kansas City Chiefs (19S7).

Harrell 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, Harrell has experienced cognitive difficulties

including, but not limited to headaches, dizziness, depression, fatigue, sleep problems, irritably,
neck and cervical arthritis and associated numbness/tingling.

43.

Plaintiff Cliff Harris ("Harris") is 62 years old and resides in Rockwall,

Texas. He was an NFL defensive back who played for the Dallas Cowboys (1970-79). He was a
six-time Pro Bowl selection (1974-79) and was a four-time All-Pro selection (1975-78). He was
voted as a member of the NFL's 1970s All-Decade Team, played in hve Super Bowls and is a
member of the Dallas Cowboys' prestigious Ring of Honor. In 2004Harris was a hnalist for the
Pro Football Hall of Fame. Harris 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, Harris has experienced
cognitive difficulties.

44.

Plaintiff Victor Hicks ("Hicks") is 54 years old and resides in Carrollton,

Texas. He was an NFL tight end who played for the Los Angeles Rams (1980). Hicks 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, Hicks has experienced cognitive diff,rculties.

45.

Plaintiff Don Horn ("Horn") is 66 years old and resides in Colorado

Springs, Colorado. He was an NFL quarterback who played for the Green Bay Packers (1967-

l3