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, )

61.

Plaintiff Mervin Krakau (ooKrakau") is 60 years old and resides in Guthrie

Center, Iowa. He was an NFL linebacker who played for the Buffalo Bills (1973-78), and the

New England Patriots (1978). Krakau 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, Krakau

has

experienced cognitive diffi culties.

62.

Plaintiff Paul Krause ("Krause") is 69 years old and resides with his wife

in Minnesota. He was an NFL defensive back for the Washington Redskins (1964-67), and the
Minnesota Vikings (1968-79). He was an eight-time selection to the Pro Bowl (1964-65,69,7175), was an eight-time All-Pro selection (1964-65,68-73,75), holds the NFL record for career
interceptions (81), and was a member of four Super Bowl teams (IV, VIII, IX,

XI).

He was

voted into the Pro Football Hall of Fame in 1998. Krause 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, Krause has experienced cognitive difficulties.

63.

Plaintiff Robert "Bob" Kroll ("Kroll") is 6lyears old and resides in

Longwood, Florida. He was an NFL defensive back who played for the Green Bay Packers

(1972). Kroll 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,

64.

Kroll

has experienced cognitive difficulties.

Plaintiff Charles Krueger ("Krueger") is 74 years old and resides in

Clayton, California. He was an NFL defensive tackle who played for the San Francisco 49ers

(1959-73). He was a two-time Pro Bowl selection, and three-time All-Pro. Krueger suffered
repeated and chronic head impacts during his career in the NFL and is at an increased risk

latent brain disease. As a result, Krueger has experienced cognitive difficulties.

l9

of

65.

Plaintiff Bruce Laird ("Laird") is 61 years old and resides with his wife in

Towson, Maryland. He was an NFL defensive back who played for the Baltimore Colts (197281), and the San Diego Chargers (1982-83). Laird was selected to the Pro Bowl in1972, and was
voted All-Pro that same year. Laird 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, Laird has experienced
cognitive difflrculties including, but not limited to headaches, loss of memory, depression, sleep
problems, and neck and cervical numbness/tingling.

66.

Plaintiff MacArthur Lane ('ol,ane") is 69 years old and resides in Oakland,

California. He was an NFL running back who played for the St. Louis Cardinals (1968-71), the
Green Bay Packers (1972-74), and the Kansas City Chiefs (1975-78). Lane was selected to the
1970 Pro

Bowl. Lane 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, Lane has experienced cognitive

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

67.

Plaintiff Gene Lang ("Lang") is 49 years old and with his wife resides in

Denver, Colorado. He was an NFL running back who played for the Denver Broncos (1984-87),
and the Atlanta Falcons (1988-90). Lang 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, Lang has

experienced cognitive difficulties including, but not limited to headaches, dizziness, loss

of

memory, depression, fatigue, sleep problems, irritability, numbness, and tingling in neck and
cervical spine.

20

68.

Plaintiff PeterLazetich("Lazetich") is 61 years old and resides in Reno,

Nevada. He was an NFL defensive end who played for the San Diego Chargers (1972-75), and
the Philadelphia Eagles (1976-78). Lazetich 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, Lazetich 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 arthritis and associated numbness/tingling

69.

Plaintiff Estate of Gregory Lens ("Lens") is deceased and was

a resident

of West, Texas. He was an NFL defensive tackle who played for the Atlanta Falcons (1970-72).
Lens suffered repeated and chronic head impacts during his career in the NFL and suffered latent

brain disease. Prior to his death, Lens experienced cognitive difhculties including, but not

limited to headaches, dizziness, loss of memory, dementia, CTE, Alzheimer's, impulse control
problems, depression, suicidal thoughts, fatigue, sleep problems, and irritability.

70.

Plaintiff Donald Macek ("Macek") is 57 years old and resides in

Escondido, California. He was an NFL center who played for the San Diego Chargers (1976-

89). In 2004Macek was voted into the

San Diego Chargers'

Hall of Fame and is a member of

the 50 Greatest Chargers team. Macek 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, Macek has

experienced cognitive difficulties including, but not limited to headaches, loss of memory, sleep
problems, initability, neck and cervical spine arthritis and associated numbness/tingling.

71.

Plaintiff Donald Manoukian ("Manoukian") is 77 years old and resides in

Reno, Nevada. He was an NFL offensive guard who played for the Oakland Raiders (1960).

Manoukian suffered repeated and chronic head impacts during his career in the NFL and is at an

2t

increased risk of latent brain disease. As a result, Manoukian has experienced cognitive

difficulties including, but not limited to headaches, dizziness, vertigo, sleep problems, neck and
cervical spine arthritis and associated numbness/tingling.

72.

Plaintiff Rod Martin ("Martin") is 57 years old and resides in Manhattan

Beach, Californa. He was an NFL linebacker for the Oakland/L.A. Raiders (1977-88). Martin
was a member of the Raiders' Super Bowl XV and

XVIII Championship

teams, and holds the

Super Bowl record for interceptions in one game with three. He was a two-time selection to the

Pro Bowl (1983-84), and was a two-time All-Pro selection (1982-84). Martin 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, Martin has experienced cognitive difficulties including, but not limited to
headaches, dizziness, loss of memory, irritability numbness/tingling in neck and cervical spine.

73.

Plaintiff Ira Matthews III ("Matthews") is 54 years old and resides in

Missouri City, Texas. He was an NFL running back who played for the Oakland Raiders (1979-

81). Matthews was named All-Pro in 1979, set a Monday Night Football record with a 104 yard
kick-off return for

a touchdown (October

25,1979), and was a member of the Raiders' Super

Bowl XV Championship team. Matthews 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, Matthews

has

experienced cognitive difhculties.

74.

Leonard "Bubba" McDowell, Jr. ("McDowell") is 44 years old and resides

in Richmond, Texas. He was an NFL safety who played for the Houston Oilers (1989-94), and
the Carolina Panthers (1995). McDowell 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, McDowell has

22

experienced cognitive difficulties including, but not limited to headaches, dizziness, loss

of

memory, fatigue, sleep problems, neck and cervical arthritis and associated numbness/tingling.

75.

Plaintiff Jeff Mclntyre ("Mclntyre") is 56 years old and resides in

Phoenix, Arizona. He was an NFL linebacker who played for the Denver Broncos (1979), the
San Francisco 49ers (1980), and the St. Louis Cardinals (1981-82).

Mclntyre 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, Mclntyre has experienced cognitive difficulties including, but not limited to
loss of memory, depression, fatigue, sleep problems, neck and cervical spine arthritis and
associated numbness/tingling.

76.
San Diego,

Plaintiff Dennis McKnight ("McKnight") is 52 years old and resides in

California. He was an NFL offensive guard who played for the San Diego Chargers

(1982-89), the Detroit Lions (1990-92), and the Philadelphia Eagles (1991). McKnight 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, McKnight has experienced cognitive difficulties including, but

not limited to headaches, loss of memory, depression, suicidal thoughts, sleep problems,

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

77.

Plaintiff Jon Melander ("Melander") is 44 years old and resides in

Victoria, Minnesota. He was an NFL offensive guard who played for the New England Patriots
(1991), the Cincinnati Bengals (1992) and the Denver Broncos (1993-94). Melander 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, Melander has experienced cognitive difficulties including, but

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

23