manatt
manatt | phelps | phillips
Ronald S. Katz
Manatt, Phelps & Phillips, LLP
Direct Dial: (650) 812-1346
E-mail: rkatz@manatt.com
1001 Page Mill Road, Building 2, Palo Alto, California 94304-1006 Telephone: 650.812.1300 Fax: 650.213.0260
Albany | Los Angeles | New York | Orange County | Palo Alto | Sacramento | Washington, D.C.
August 10, 2007
Client-Matter: 29749-060
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 v. National Football League Players Association
Case No. C07-0943 WHA
Dear Judge Alsup:
We represent Plaintiffs Bernard Paul Parrish, Herbert Anthony Adderley, and Walter Roberts
III (collectively, “Plaintiffs”) in the above-referenced class action. Plaintiffs submit this letter brief
pursuant to Paragraph 26 of the Court’s Supplemental Standing Order. Plaintiffs respectfully request
an Order from this Court compelling Defendant National Football League Players Incorporated d/b/a
Players Inc (“PLAYERS INC”) to produce the documents identified below in response to Plaintiffs’
June 15, 2007 Document Requests.
PLAYERS INC’s Financial Statements
Document Request No. 12 calls for “PLAYERS INC’s financial statements from January 1,
1997 to the date of production.” PLAYERS INC objected to this Request on the ground that, among
other things, the term “financial statements” is vague and ambiguous. PLAYERS INC has indicated
that it will only produce documents that are specifically related to retired NFL player rights (as
unilaterally determined by PLAYERS INC). Plaintiffs respectfully request that this Court order
PLAYERS INC to produce those financial statements responsive to this clear and narrow request, and
not just those documents that PLAYERS INC considers to be related to retired NFL players.
The information sought in this Request is not only relevant, it goes to the heart of Plaintiffs’
claims. The crux of Plain