D E W E Y BA LLA NT IN E LLP
1301 AVENUE OF THE AMERICAS
NEW YORK, NEW YORK 10019-6092
TEL 212 259-8000 FAX 212 259-6333
JEFFREY L. KESSLER
September 4, 2007
VIA ELECTRONIC FILING
The Honorable William Alsup
United States District Court, Northern District of California
450 Golden Gate Avenue
San Francisco, CA 94102
Re: Parrish, et al. v. National Football League Players Ass’n, et al.
Case No. 07-0943 WHA
Dear Judge Alsup:
We represent the Defendants in the above-captioned matter and make this
submission in response to the Court’s August 30, 2007 Order Re: GLA Signed By
Adderley And Dues Paid By Plaintiffs. Enclosed is a sworn declaration from Andre
Collins, the Director of the NFLPA Retired Players Department.
As set forth in Mr. Collins’s Declaration, while Mr. Parrish did not pay
any NFLPA Retired Players Association dues during the period 2000 to 2004, in 2005,
Mr. Parrish paid $50 in such dues. I apologize for making an inaccurate statement to the
Court on this point. Based on initial investigation, I erroneously had been led to believe
that Mr. Parrish had not paid any dues to the NFLPA Retired Players Association during
the entire statute of limitations period.
Mr. Collins’s Declaration confirms, as discussed at the recent hearing, that
Mr. Adderley did pay NFLPA Retired Players Association dues during the statute of
limitations period ($50 payments in 2003, 2004, and 2005), and that Mr. Roberts did not
pay any such dues at any time.
We reiterate, however, as stated in our briefs in support of Defendants’
motions to dismiss, that Plaintiffs have not alleged a cognizable nexus between the $50
dues payments of Messrs. Parrish and Adderley and any of their causes of action.
Moreover, there is no allegation of California in-state conduct related to these dues
payments, and such payments thus cannot possibly give rise to a Section 17200 injury
claim with respect to non-California residents Messrs. Parrish an