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, )

78.

Plaintiff Michael Merriweather (o'Merriweather") is 50 years old and

resides in Stockton, California. He was an NFL linebacker for the Pittsburgh Steelers (1982-87),

the Minnesota Vikings (1989-92), the New York Jets (1993), and the Green Bay Packers (1993).
He is a three-time Pro Bowl selection (1984-86), and a three-time All-Pro Selection (1984-85,
87). Meniweather 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, Merriweather 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.

79.

Plaintiff Tenance "TeÍry" Metcalf ("Metcalf') is 60 years old and resides

in Seattle, Washington. He was an NFL running back who played for the St. Louis Cardinals
(1973-77), and the Washington Redskins (1981). Metcalf was selected to 3 Pro Bowls (1974,
1975, and 1977), and was an All-Pro selection in 1975. Metcalf hold the NFL record for number

of games with 250+ all purpose yards, with 7. Metcalf 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, Metcalf has experienced cognitive difhculties including, but not limited to headaches,
dizziness,loss of memory, depression, sleep problems, irritability, neck and cervical spine

arthritis and associated numbness/tingling.

80.

Plaintiff Caleb Miller ("Miller") is 31 years old and resides in Florence,

Kentucky. He was an NFL middle linebacker who played for the Cincinnati Bengals (2004-07).

Miller 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,

Miller

has experienced cognitive diff,rculties

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

24

depression, suicidal thoughts fatigue, sleep problems, irritability, numbness and tingling in neck
and tingling.

81.

Plaintiff Kory Minor ("Minor") is 34 years old and resides in Moreno

Valley, Califomia. He was an NFL linebacker who played for the Carolina Panthers (19992002). Minor 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, Minor has experienced cognitive diff,rculties

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

82.

Plaintiff Derland Moore (ooMoore") is 60 years old and resides in

Mandeville, Louisiana. He was an NFL defensive tackle for the New Orleans Saints (19731985), and the New York Jets (1986). He was selected to play in the 1983 Pro Bowl, set a Saints
team record for service with 169 games played, and is a member of the New Orleans Saints Hall

of Fame. Moore 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, Moore has experienced cognitive

difficulties.

83.

Plaintiff Michael Morton ("Morton") is 51 years old and resides in Wesley

Chapel, Florida. He was an NFL running back who played for the Tampa Bay Buccaneers
(1982-84), the Washington Redskins (1985), and the Seattle Seahawks (1987). Morton 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, Morton has experienced cognitive difficulties including, but not

limited to headaches, dizziness, loss of memory, fatigue, irritability, and numbness/tingling in
neck and cervical spine.

25

84.

Plaintiff Charles Myrtle ("Myrtle") is 66 years old and resides in

Bethesda, Maryland. He was an NFL running back who played for the Denver Broncos (1967 -

72), and the San Diego Chargers (1974). Myrtle 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,

Myrtle has experienced cognitive difhculties including, but not limited to headaches, dizziness,
loss of memory, neurological disorder, depression,

initability, double vision, neck and cervical

arthritis and associated numbness/tingling.

85.

Plaintiff Mark Nichols ("Nichols") is 52 years old and resides in

Bakersflreld, California. He was an NFL wide receiver who played for the Detroit Lions (193189). Nichols 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, Nichols has experienced cognitive difficulties

including, but not limited to headaches, dizziness, loss of memory, dementia, impulse control
problems, Alzheimer's, depression, fatigue, sleep problems, irritability, neck and cervical spine

arthritis and associated numbnessitingling.

86.

Plaintiff Tommy Nobis ("Nobis") is 68 years old and resides with his wife

in Atlanta, Georgia. He was an NFL linebacker who played for the Atlanta Falcons (1966-76).
He was the first ever player drafted by the expansion Falcons in 1966 and was voted NFL
Defensive Rookie of the Year. He was a five-time Pro Bowl selection (1966-70,1972),was
selected All-Pro (1967), and was voted to the

NFL's

1960s All-Decade

Team. Nobis 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, Nobis has experienced cognitive difficulties including, but not

limited to headaches, loss of memory, dementia, depression, fatigue, sleep problems,
numbness/tingling in neck and cervical spine.

26

87.

Plaintiff Keith Nord ('Nord") is 54 years old and resides in Minnesota.

He was an NFL defensive back who played for the Minnesota Vikings (1979-85). Nord 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, Nord has experienced cognitive diffrculties including, but not

limited to headaches, dizziness, loss of memory, depression, fatigue, sleep problems, irritability,
neck and cervical arthritis and associated numbness/tingling.

88.

Plaintiff August "Gus" Otto ("Otto") is 68 years old and resides in

Chesterfield, Missouri. He was an NFL linebacker who played for the Oakland Raiders (1965-

72). Otto was a member of the Raiders' first Super Bowl team (Super Bowl II), which they lost
to the Green Bay Packers. Otto 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, Otto has experienced

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

89.

Plaintiff Terry Owens ("Owens") is 67 years old and resides with his wife

in Decatur, Alabama. He was an NFL offensive tackle who played for the San Diego Chargers
(1966-75). Owens 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, Owens has experienced cognitive

difficulties including, but not limited to headaches, dizziness, loss of memory, dementia, impulse
control problems, depression, suicidal thoughts, fatigue, sleep problems, peripheral neuropathy,
neck and cervical arthritis and associated numbnessitingling.

90.

Plaintiff Gary Padjen ("Padjen") is 53 years old and resides in Carmel,

lndiana. He was an NFL linebacker who played for the Baltimore/Indianapolis Colts (1982-87).
Padjen 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, Padjen has experienced cognitive difficulties

27

including, but not limited to headaches, dizziness, loss of memory, impulse control problems,
depression, suicidal thoughts, fatigue, sleep problems, irritability, neck and cervical spine

arthritis and associated numbness/tingling.

91.

Plaintiff Randy Ragon ("Ragon") resides in Lahaina, Hawaii. He was an

NFL wide receiver who played for the Buffalo Bills (1978). Ragon 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, Ragon has experienced cognitive difficulties including, but not limited to headaches,
dizziness, loss of memory, depression, suicidal thoughts, fatigue, initability, neck and cervical
spine arthritis and associated numbness/tingling.

92.

Plaintiff David Recher ("Recher") is 68 years old and resides in Gilbert,

Arizona. He was an NFL center who played for the Philadelphia Eagles (1965-68). Recher
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, Recher has experienced cognitive diffrculties.

93.

Plaintiff Jeny Robinson ("Robinson") is 54 years old and resides in Santa

Rosa, California. He was an NFL linebacker who played for the Philadelphia Eagles (1979-84),
and the Los Angeles Raiders (1985-92).

In 1981 he was selected to the Pro Bowl,

and was voted

All-Pro. He was also a member of the Eagles Super Bowl XV team. Robinson 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, Robinson has experienced cognitive difhculties including, but not limited to
headaches, dizziness, loss of memory, neurological disorder, depression, suicidal thoughts,

fatigue, sleep problems, irritability, and numbness/tingling in neck and spine.

94.

Plaintiff Rick Sanford ('oSanford") is 54 years old and resides in Irmo,

South Carolina. He was an NFL defensive back who played for the New England Patriots

28