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, )

70), the Denver Broncos (1971-72), and the Cleveland Browns (1973-74). Horn 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, Hom has experienced cognitive difficulties including, but not

limited to dizziness, impulse control problems, depression, fatigue, sleep problems, irritability,
and numbness/tingling in neck and cervical spine.

46.

Plaintiff James Hough ("Hough") is 55 years old and resides with his wife

in Chaska, Minnesota. He was an NFL offensive guard who played for the Minnesota Vikings
(1978-86). Hough 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, Hough has experienced cognitive

difficulties including, but not limited to headaches, dizziness, loss of memory, neurological
disorder fatigue, sleep problems, irritability, neck and cervical spine arthritis and associated
numbness/tingling.

47.

Plaintiff Delles Howell ("Howell") is 63 years old and resides with his

wife in Montoe, Louisiana. He was an NFL defensive back who played for the New Orleans
Saints (1970-72), and the New York Jets (1973-75). Howell 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, Howell has experienced cognitive difficulties including, but not limited to headaches,
dizziness, loss of memory, fatigue, sleep problems, neck and cervical spine arthritis and
associated numbness/tingling.

48.

Plaintiff Brad Jackson ("Jackson") is 36 years old and resides in

Pikesville, Maryland. He was an NFL linebacker who played for the Miami Dolphins (1998),
the Baltimore Ravens (1998-01), and the Carolina Panthers (2002). Jackson was a member
the Ravens' Super Bowl

XXXV Championship team.

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Jackson 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, Jackson has experienced cognitive difficulties including, but not limited to headaches,
dizziness, loss of memory, fatigue, sleep problems, irritability, neck and cervical spine arthritis
and associated numbnessitingling.

49.

Plaintiff Calvin Jackson ("C. Jackson") is 39 years old and resides in

Pompano, Florida. He was an NFL defensive back who played for the Miami Dolphins (1994-

99). C. Jackson 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, C. Jackson has experienced cognitive

difficulties including, but not limited to headaches, dizziness, loss of memory, impulse control
problems, depression, fatigue, sleep problems, irritability, neck and cervical spine
numbness/tingling.

50.

Plaintiff J. Bruce Jarvis ("Jarvis") is 62 years old and resides in

Sammamish, V/ashington. He was an NFL center who played for the Buffalo Bills (1971-74).
Jarvis 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, Jarvis has experienced cognitive difficulties

including, but not limited to headaches, dizziness, loss of memory, impulse control problems,
depression, fatigue, sleep problems, irritability, neck and cervical arthritis and associated
numbness/tingling.

51.

Plaintiff Leon

ooRay"

Jarvis ("R. Jarvis") is 62 years old and resides with

his wife in Brookfield, Wisconsin. He \¡/as an NFL wide receiver who played for the Atlanta
Falcons (1971-72), the Buffalo Bills (1973), the Detroit Lions (1974-78), and the New England
Patriots (1979). R. Jarvis 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, R. Jarvis has experienced

l5

cognitive diffrculties including, but not limited to headaches, dizziness, loss of memory,
depression, fatigue, sleep problems, irritability, neck and cervical spine arthritis and associated

numbness/tingling.

52.

Plaintiff Noel Jenke ("Jenke") is 64 years old and resides in Brookfield,

Wisconsin. He was an NFL linebacker for the Minnesota Vikings (1971), the Atlanta Falcons
(1972), and the Green Bay Packerc (1974). Jenke 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, Jenke
has experienced cognitive difhculties including, but not limited to headaches, dizziness, loss

of

memory, and stroke (2008).

53.

Plaintiff Olrick Johnson, Jr. ("Johnson") is 34 years old and resides in

Miami, Florida. He was an NFL linebacker who played for the New York Jets (1999), the
Minnesota Vikings (1999), and the New England Patriots (2000). Johnson 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, Johnson has experienced cognitive difflrculties including, but not limited to
seizures, epilepsy, headaches, dizziness, loss of memory, depression, fatigue, sleep problems,

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

54.

Plaintiff Troy Johnson ("T. Johnson") is 49 years old and resides in

Chauvin, Louisiana. He was an NFL wide receiver who played for the St. Louis Cardinals
(1986-87), the Pittsburgh Steelers (1988), the Detroit Lions (1989), and the San Diego Chargers

(1990). T. Johnson 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, T. Johnson has experienced cognitive

diffrculties including, but not limited to headaches, dizziness, loss of memory, impulse control

t6

problems, depression, fatigue, sleep problems, irritability, neck and cervical spine arthritis and
associated numbness/tingling.

55.

Plaintiff Trumaine Johnson ("Tru.Johnson") is 51 years old and resides

with his wife in Baton Rouge, Louisiana. He was an NFL wide receiver who played for the San
Diego Chargers (1985-86), and the Buffalo Bills (1987-89). Tru. Johnson 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, Tru. Johnson has experienced cognitive difficulties including, but not

limited to headaches, dizziness, depression, suicidal thoughts, fatigue, sleep problems,

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

56.

Plaintiff Aaron Jones II ("Jones") is 44 years old and resides with his wife

in Orlando, Florida. He was an NFL defensive end for the Pittsburgh Steelers (1988-92), the
New England Patriots (1993-95), and the Miami Dolphins (1996). Jones 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, Jones has experienced cognitive difficulties including, but not limited to
headaches, dizziness, loss of memory, impulse control problems, neurological disorder,
depression, suicidal thoughts, fatigue, sleep problems, irritability, and numbness/tingling in neck
and cervical spine.

57.

Plaintiff James Jones ("J. Jones") is 50 years old and resides in Tampa,

Florida. He was an NFL fullback who played for the Detroit Lions (1983-88, 93), and the Seattle
Seahawks (1989-92). Jones 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, Jones has experienced

cognitive difficulties including, but not limited to headaches, dizziness, loss of memory, sleep
problems, irritability, neck and cervical arthritis and associated numbnessitingling.

t7

58.

Plaintiff Steve Jones ("S. Jones") is 60 years old and resides in St. Louis,

Missouri. He was an NFL running back who played for the Buffalo Bills

(1973 -74), and the St.

Louis Cardinals (1974-78). S. Jones 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, S. Jones has
experienced cognitive difficulties including, but not limited to dizziness, loss of memory, fatigue,
sleep problems, irritability, neck and cervical spine numbness/tingling.

59.

Plaintiff Joseph Kapp ("Kapp") is 73 years old and resides with his wife in

Los Gatos, California. He was an NFL quarterback who played for the Minnesota Vikings
(1967-69), and the Boston Patriots (1970). Kapp was selected to the 1969 Pro Bowl. In
September 1969, Kapp set an NFL record by throwing 7 touchdown passes in a single game.

Kapp led the Vikings to Super Bowl IV, where they lost to the Kansas City Chiefs. Kapp
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, Kapp has experienced

cognitive difficulties including,

but not limited to headaches, dizziness, loss of memory, dementia, impulse control problems,
neurological disorder, depression, fatigue, sleep problems, irritability, neck and cervical arthritis
and associated numbness/tingling.

60.

Plaintiff Mark Koncar ("Koncar") is 58 years old and resides with his wife

in Alpine, Utah. He was an NFL offensive tackle who played for the Green Bay Packers (197681), and the Houston Oilers (1982-83). Koncar 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,
Koncar has experienced cognitive difficulties including, but not limited to headaches, dizziness,
loss of memory, dementia, depression, suicidal thoughts, fatigue, sleep problems, irritability, and
neck and cervical spine arthritis.

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