Concussion Lawsuit vs. NFL

8/6/2019 Concussion Lawsuit vs. NFL

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1 GIRARD! I KEESE O R \ G \ N A L ' l \ ~

mOMAS V: GIRARDI, Bar No, 36603 /\'d.~\\\)\2 1126 Wilshire Boulevard - \ ,\)3 Los Angeles, California 90017Telephone: (213) 977-0211

4 Facsimile: (213)481-15545 RUSSOM ANNO & B OR RELL O, P.A .

H erm an Russo manno , (Flo rida Bar No . 240346)6 R obert B orrello , (F lo rida B ar N o. 764485)150 W est F lagler Street - PH 28007 Miami, FL 33130Telephone: (305) 373-21018 Facsimile: (305) 37~-2103

9 G OLD BER G, PER SK Y & W ID TE, P.C .10 Jaso n E. L uckasevic, (pennsylvania B ar N o. 85557)

J ohn T . T ie rn ey , illPennsylvania B ar N o. 00287)11 1030 F ifth A ve .P itt sb ur gh , PA 1521912 Telephone: (412) 471-3980 .

Facsimile: (412) 471-83081314 Attorneys for Plaintiffs

' ., FILEDSUPER IOR COURTOFCAUFORNCOUN'l"V OP LOS ANGELFSJ U l 19,2011

, Execu tive Of fice r /C ter---'l~==";rr-r---' Depu

SUPERIOR COURT OF THE STAT E OF CALIFORNIACOUNTY OF LOS ANGELES B Y F A X

VERNON MAXWELL; BRODERICK )JONES; KENDALL W ILLIAMS and )INGRID W ILLIAMS, his wife; MIKE C. )RICHARDSON ; RENARD YOUNG and )VANESSA YOUNG , his w ife; LONZELL ).H ILL and LANIT A HILL , his w ife; )GEORGE VISGER and KR lSTIE )V ISGER , his w ife; TERRY WRIGHT; )N EW TON W IL LIAMS; DUANE )GALLOWAY; GEORGE JAM ISON and )ARNELLA JAM ISON , his w ife; BRYAN )HOOKS; FRED MCNEILL and TIA )MCNEILL, his w ife; REG INALD , )ROGERS, SR .~ MELVIN JENKINS and )JA VONI JENKINS, his w ife; ANTONIO )G IBSON and BETTY GIBSON , his w ife; )ALVIN MOORE and ODETT A MOORE. )

CASE NO . B C 4 6 5 8 4 2PLAINTIFFS'. COMPLAINT FORDAMAGES AND DEMAND FOR JURY-TRIAL1. N eglig en ce - M o no po list2. Negligence3. Fraud4 . Negligence5. Strict L iability - D esig n D efect 'R; ~ $: i}; ~

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1 his w ife; L YVONIA A. M IT CH EL L; K IR K)CAM ERON JON ES; JAM ES E. ROBB INS)2 and SH AN EE TA R OB BIN S, his wife; )ROBERT 1. FREDRICKSON and )3 BARBARA FREDR ICKSON , his w ife; )4 CHARLES E . M ILLER ; EDWARD P. LEE)and SUSAN LEE, his w ife; PATR ICK )5 .HEENAN and SHARRON HEENAN , his )

w ife ; TOBY LR IG HT ; K EL LY )6 KIRCHBAUM ; ):., JAMES HOOD and BONITA HOOD , his ). w ife; R ICHARD M ERCIER and Y AD IRA )8 MERCIER , his w ife; )

BRETT ROM BERG and EM ILY )9 ROMBERG , his w ife; STEVE KORTE and )K AR EL IS K OR TE , his w ife; JO E HARR IS )1 0 and LYD IA HARRIS , his w ife; RODNEY )11 HAMPTON and ANDETRIA HAMPTON , )his w ife; LEW IS D . TILLMAN and .)12 KATHY TILLMAN , his w ife; LARRY )

KAMINSKI an d L IN DA KAMINSKl, his ).13 wife; DAVID KOCOUREK and rvIARY )14 LEE KOCOUREK , his w ife; ROBERT )W EA TIIERS and DEN ISE WEATHERS, )15 his w ife; W A YN E HAWKINS "and )1 6 SHARON HAWKINS, his w ife; )ANTHONY HARGAIN ; EDWARD )17 PAYTON and R ICA PAYTON , his w ife; )

W ILLIAM H . MANDLEY and TERESA )1 8 M ANDLEY , his w ife; SHANTE CARVER ;)GEORGE GOEDDEKE and GENEVA )1 9 GOEDDEKE, his w ife; JAM ES :M 1CHAEL )20 SCHNITKER and B EVERLEE )SCHNITKER , his w ife; CHRISTOPHER )21 C ALLOWAY; )

THOMAS C . RANDOLPH , II and )22 EVEL YN RANDOLPH , his w ife; GARY )23 JONES and TINA JONES, his w ife; OTTIS )

ANDERSON and WANDA ANDERSON , )24 his w ife; LEONARD RUSSELL and )25 TASHA RUSSELL, his w ife; RORY )GRAVES; DAVID M . WHITE and )26 MONICA WHITE , his w ife; PH ILIP )SM ITH and GA IL SM ITH ; W . VERNON )27 DEAN ; ANTHONY COVINGTON ; )28 ANTHONY JONES and V ALER lE )

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1 JON ES, his w ife; STEV E REESE and )M ARILYN REESE , his w ife; DO NA LD )2 B ES SIL LIE U; H ARO LD 1. JACKSON )3 and CA RO L YN JA CK SON , his w ife; )TODD JOHNSON and SHANNON )4 JO HN "S ON , his w ife; C HR IS G OO DE ; )BR UC E W ALK ER and V A NISH A )5 W ALKER , his w ife; DERRICK S. )6 REYNOLDS; DA VrD LEW IS and ).B ON NIE L EW IS, his w ife; R ON NIE )7 LIPPET I and SHERYL LIPPETT , his )wife; RO LAN J? JAM ES and CARM EL )8 JA MES, his w ife; M ARK S . DU PER ; )9 BRIAN INGRAM and SARCA INGRAM , )h is w ife; A NT IIO NY CO LLIN S and )

10 TRU DY COLLINS, his w ife; STEV E )NELSON and ANGELA NELSON , his )11 w ife; JA MES E. W ILL IS and SH ALAN E )12 W ILLIS , his w ife; A NTH ON Y H AN CO CK )and PA ULA H AN CO CK , his w ife; JEFF )13 BURRIS; W ILLIAM : C . BRAD LEY and )SU SAN BRAD LEY , his w ife; KERRY )14 GOODE and T AN JA GOODE, his w ife; )RAYM OND CLAYBORN and )15 K IM BERLEY CLA YBORN , his w ife; )16 STEVEN ZABEL and SUSAN ZABEL , his)wife, )17 )

Plaintiffs, )18 )19 vs. ))20 NATIONAL FOOTBALL LEAGUE ; NFL )PR OPERT IE S LLC ; R ID DEL L, IN C. d/b /a)21 R IDDELL SPORTS GROUP, INC ., ALL )22 AMERlCAN S PORTS CORPORAT ION , )d/b /a R ID DE LL /A LL AM ER IC AN ; )23 R IDDELL SPORTS GROUP, INC , )E AST ON -B ELL SPO RTS, IN C.; )24 EASTON -BELL SPORTS, LLC ; EB )25 SPO RTS CO RP .; and RBG H OLD ING S )CORP.; and JOHN DOES 1 th ro ugh 1 0 0 , )26 Inclus ive, ))27 Defendants . )~~ )J 28" ,~\. ? -3 -,~I\

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Mr. Mike C. Richardson is.a resident of and domiciled in the State of California.Mr. Renard Young and his wife, Vanessa, are residents of and domiciled in the State

1 The Plaintiffs, all individuals, hereby complains of Defendants listed above and hereby alleges2 as follows:3 PARTIES4 P l a i n t i f f s :5 1. . M r. Vernon Maxwell is a resident of and domiciled in the State of Arizona.6 2. Mr. Broderick Jones is a resident of and domiciled in the State of Alabama.7 3. Mr. Kendall Williams and his wife, Ingrid, are residents of and domiciled in the State8 of Nevada.9 4.

10 5.11 of California.12 6.13 Ohio.14 7.15 California.16 8 .17 9.18 10.19 1 1 .20 of Michigan.21 1 2.22 1 3 .23 California.24 14.25 15.26 of Arizona.27~.~.J

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Mi. LonZell Hill and his wife, Lanita, are residents of and domiciled in the State of

Mr. GeorgeVisger and his wife, Kritsie, are. residents of and domiciled in the State a

Mr. Terry wdght is a resident of and domiciled in the State of Arizona.Mr. Newton Williams is a resident of and domiciled in the State of North Carolina.Mr. Duane Galloway is a resident of and domiciled in the State of California.Mr. George Jamison and his wife, Arnella, are residents of and domiciled in the State

M r. Bryan Hooks is a resident of and domiciled in the State of Arizona.Mr. Fred McNeill and his wife, Tia, are residents of and domiciled in the State of

Mr. Reginald Rogers, Sr. is a resident of and domiciled in the State of Washington.M r. Melvin Jenkins and his wife, Javoni, are residents of and domiciled in the State

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CO MPLA IN T FO R D AM AGES


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Mr. Jam es E . R obb ins and his w ife , Shane eta , are residents o f and. do miciled in th e8 S tate o f A rizo na.9 21 . M r. R obert J. Fredrickso n and h is w ife , B arbara, are residents o f anddo miciled in the

10 S ta te o f A riz on a.M r. C harles E . M iller is a resident o f and do miciled in th e S ta te o f C alifo rn ia .M r. Edw ard P. L ee and his w ife , Susan, are residen ts o f and dom iciled in the S tate o f

1 1 6.2 Texas .3 17.4 Arizona.5 18 .'6 1 9 .7 20 .

11 22.12 23.13 Maryland.14 24.15 o f Tennes se e .16 25;17 26.18 27 . .1 9 California.20 28.21 o f F lo r id a.22 29 .23 Florida.24 30 .25 Louisiana.26 31 .27 Georgia .e ~,'J" 28~.~ O .:-\" , ~~,~

Mr. A nto nio G ibso n and his w ife , B etty , are residents o f and do miciled in th e S ta te 0

Mr.A lvin M o ore and his w ife , O detta , are residents o f and do miciled in the S tate o f

Mr.L yvo nia A . M itchell is a resident o f and do miciled in the S tate o f L ouisiana.M r. K irk C am ero n Jo nes is a resident o f and do miciled in the S tate o f F lo rida .

M r. Patrick H eenan and his w ife, Sharro n, are residents o f and do miciled in th e S tate

Mr. Toby L.W right is a residen t o f and do miciled in the Sta te o f A rizo na.M r. K elly K irchbaum is a resident o f and do miciled in th e S ta te o f K en tu ck y.M r. Jam es H oo d and his w ife, B on ita , are residents o f and do miciled in the S ta te o f

M r. R ichard M ercier and his w ife, Y adira, are residents o f and do miciled in the S tate

M r. B rett R om berg and h is w ife , E mily; are residents o f and do miciled in the S tate o f

M r. Steve K orte and his w ife , K arelis, are residen ts o f and do miciled in the S tate o fMr. Jo e H arris and his w ife , L ydia , are residents o f and do miciled in the S tate o f

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1 32. Mr. Rodney Hampton and his wife, Andetria, are residents of and domiciled in the2 State of Texas.3 33. M r. Lewis D. Tillman and his wife, Kathy, are residents of and domiciled in the State4 of Mississippi.5 34. Mr . L arry Kaminski and his wife, Linda, are residents of and domiciled in the State6 of Washington.7 35 . Mr. David Kocourek and his wife, Mary Lee, are residents of and domiciled in the8 State of Florida ..

Mr. Robert Weathers and his wife, Denise, are residents of and domiciled in the State36.10 of Florida.11 37.12 of California.13 38.14 39 .15 Mississippi.16 40 .

Mr. Wayne Hawkins and his wife, Sharon, are residents of and domiciled in the State

Mr. Anthony Hargain is a resident of and domiciled in the State of California.Mr. Edward Payton and his wife, Rica, are residents of and domiciled in the State of

Mr. William H. Mandley and his wife, Teresa, are residents of and domiciled in the17 State of Arizona.18 41 . Mr. Shante Carver is a resident of and domiciled hi the State of Arizona.

. .19 42. Mr. George Goeddeke and his wife, Geneva, are residents of and domiciled in the20 State of Michigan.21 43. M r. James Michael Schnitker and his wife, Beverlee, are residents of and domiciled22 in the State of Colorado.23 44. Mr. Christopher Calloway is a resident of and domiciled in the State of Georgia.24 45. Mr. Thomas C Randolph, II and his wife, Evelyn, are residents of and domiciled in25 the State of Virginia.26 46. Mr. Gary Jones and his wife, Tina, are residents of and domiciled in the State of27 texas.

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Mr.Philip Smith and his wife, Gail, are residents of and domiciled in the State of

1 47. Mr. Ottis Anderson and his wife, Wanda, are residents of and domiciled in the State2 of New Jersey.3 .48.' Mr. Leonard Russell and his wife, Tasha, are residents of and domiciled in the State

Mr.Donald Bessillieu is a resident of and domiciled in the State of Georgia.Mr. Harold L. Jackson and his wife, Carolyn, are residents of and domiciled in the

18 State of California.Mr. Todd Johnson and his wife, Shannon, are residents of and domiciled in the State

4 of California.5 49.6 50 .7 of New York.8 51.-9 California.10 5 2 . .11 53.12 54.13 of Alabama.14 55.15 Georgia.16 56.17 57.

19 58.20 of Florida.21 59.22 6 O .23 of California.24 61.25 62.26 Florida.27e~:~ 28\r~~ O,.~r "y ..

Mr. Rory Graves is a resident of and domiciled in the State of Georgia.Mr. David M. White and his wife, Monica, are residents of and domiciled in the State

Mr. W. Vernon Dean is a resident of and domiciled in the State of Texas.Mr. Anthony Covington is a resident of and domiciled in the State of Pennsylvania.Mr. Anthony Jones and his wife, Valerie, are residents of and domiciled in the State

Mr ..Steve Reese and his wife, Marilyn, are residents of a n d domiciled inthe State of

Mr. Chris Goode is a resident of and domiciled in the State of Alabama.Mr.Bruce Walker and his wife, Vanisha, are residents of and domiciled in the State

. Mr. Derrick S. Reynolds is a resident of and domiciled in the State of Florida.Mr. David Lewis and his wife, Bonnie, are residents of and domiciled in the State of

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1 63. M r. Ronnie Lippett and his wife, Sheryl, are residents of and domiciled in the State2 of Massachusetts.3 64.0 Mr. Roland James and his wife, Carmel, are residents of and domiciled in the State 04 Massachusetts.5 65. Mr. Mark S. Duper is a resident of and domiciled in the State of Florida.6 66. Mr.Brian Ingram and his wife, Sarca, are residents of and domiciled in the State of7 Georgia.8 67. Mr. Anthony Collins and his wife, Trudy, are residents of and domiciled in the State9 of North Carolina.10 68. Mr. Steve Nelson and his wife, Angela, are residents of and domiciled in the State of11 Massachusetts.12 69. Mr. James E. Willis and his wife, Shalane, are residents of and domiciled in the State13 of Alabama.14 70. M r. Anthony Hancock and his wife, Paula, are residents of and domiciled in the State15 of Tennessee. 016 71. M r. Jeff Burris is a resident of and domiciled in the State of Indiana.17 12 . Mr. William C. Bradley and his wife, Susan, are residents of and domiciled in the18 State of Texas.19 73. Mr. Kerry Goode and his wife, Tanja, are residents of and domiciled in the State of20 Georgia.21 74. M r. Raymond Clayborn and his wife, Kimberley, are residents of and domiciled in22 the State of Georgia.23 75. M r. Steven Zabel and his wife, Susan, are residents of and domiciled in the State of24 Georgia.2526 Defendants:2728



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1 76. Defendant National Football League ("the NFL") is an unincorporated association2 with its headquarters located in the State of New York. The NFL regularly conducts business in3 California.4 77. Defendant NFL Properties, LLC as the successor-in-interest to National Football

. 5 League Properties Inc. ("NFL Properties") is a limited liability company organized and existing6 under the laws of the State of Delaware with its headquarters in the State of New York. NFL. .7 Properties is engaged, among other activities, approving licensing and promoting equipment used8 by all the NFL teams. NFL Properties regularly conducts business inCalifornia.9 78. Defendant Riddell, Inc. (d/b/a Riddell Sports Group, Inc.) is a corporation organized10 and existing under the laws of the State of Illinois, and is engaged in the business of designing,11 manufacturing, selling and distributing football equipment, including helmets, to the NFL and12 since 1989 has been the official helmet of the NFL. Riddell, Inc. regularly conducts business in13 California.14 79. Defendant All American Sports Corporation, d/b/a Riddell/All American, is a15 corporation organized and existing under the laws of the State of Delaware and is engaged in the16 business of designing, manufacturing, selling and distributing football equipment, including17 helmets, to the NFL and since 1989 has been the official helmet of the NFL. All American Sports'18 regularly conducts business inCalifornia.19 80. Defendant Riddell Sports Group, Inc. is a Delaware corporation with its principal20 place of business at 6255 N. State Highway, #300, Irving. Texas 76038. Riddell Sports Group, Inc.2! regularly conducts business in California.

81 . Defendant Easton-Bell Sports, Inc. is a California corporation, incorporated inDelaware with a principal place of business at 7855 Haskell Avenue, Suite 200, Van Nuys,California 91406 and is a parent corporation of Riddell Sports Group Inc.

82. Defendant Easton-Bell Sports, LLC is the parent corporation of Easton-Bell Sports,Inc. and is incorporated in Delaware, with a principal place of business at 152 West 57th Street,New York, New York 10019. Easton-Bell Sports, LLC regularly conducts business in California.

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1 83. Defendant EB Sports Corp. is a Delaware corporation with its principal place of2 business at 7855 Haskell Avenue, Van Nuys, California 91406.3 84. Defendant RBG Holdings Corp. is a Delaware corporation with its principal place of4 business at 7855 Haskell Avenue, Suite 350, Van Nuys, California 91406.

. .5 85. Defendants Riddell, Inc., Riddell Sports Group Inc., All American Sports6 Corporation, Easton-BellSports, Inc., EB Sports Corp., Easton-Bell Sports, LLC, and RBG7 Holdings Corp., shall hereinafter be referred to collectively a s the "Riddell Defendants."89 JURISDICTION AND VENUE10 86. Jurisdiction is based upon the California Constitution Article 6, Section 10.11 87. Venue is proper in this Court pursuant to Section 395 (A) of the California Code o f12 Civil Procedure.1314 INTRODUCTION15 88. The National Football League was founded a s the American. Professional Football16 Association in 1920.17 89. The American Professional Football Association ch~ged its name to the National

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18 Football League in 1922. By 1924, there were 23 franchises or teams that devised the NFL.19 90. The American Football League operated from 1960 to 1969. In 1970, it merged with20 the National Football League to create the American Football Conference ,21 91. Today, the National Football League consists of two structured conferences, the AFe22 and the NFC, with 32 team members.

92. Each team functions as a separate business but operates under shared revenuegenerated through broadcasting, merchandising and licensing.

93. The Supreme Court of the United States of America inAmerican Needle, Inc. v. NFL,et al., 130 S.Ct. 2201 (U.S. 2010), ruled that the NFL is a separate entity from each of its teams.

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.e1 94. The NFL is by far the most attended domestic sports league in the world by average .2 attendance per game with 67,509 fans per game in the regular season (2009).3 95. The NFL is a'9 billion dollar-a-year business.4.5 NFL AND THE CBA6 96. Until March of2011, NFL players were all members ofa union called the National7 Football League Players Association ("NFLPA"). The NFLPA negotiates the general minimum8 contract for all players in the league with the National Football League Management Council9 ("NFLMC'l This contract is called the Collective Bargaining Agreement("CBA") and it is the10 central document that governs the negotiation of individual player contracts for all of-the league's11 players. However, historically, the NFL retired players have never been the subject of or a party to12 Collective Bargaining.13 97. The CBA had been in place since 1993 and was amended in 1998 and again in2006.14 The.CBA was originally scheduled to expire at the end of the 2012 season but in 2008 the owners15 exercised their right to opt-out of the agreement two years earlier. In2011, the parties in trying to16 negotiate a new CBA reached an impasse and the NFL owners locked the pl~yers out.17 Subsequently, the NFLPA decertified itself as the players' representative for bargaining.18 98. The plaintiffs herein are all retirees and not covered by the CBA nor are they a19 subject of or parties to bargaining between the NFL and the NFLPA. Thus, the plaintiffs' claims20 are not preempted by federal labor law since the CBA does not apply to their present claims and,21 additionally, it does not currently exist.2223 CTE AND CONCUSSION INJURY24 99. In2002, Dr. Bennet Omalu, a forensic pathologist and neuropathologist found

. .25 Chronic Traumatic Encephalopathy (CTE) in the brain of Hall of Farner, Mike Webster ,26 100. By 2007, Dr. Omalu found a fourth case linking the death of a former NFL player to27 CTE brain damage from his football career.28

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CO lv fP LA INT FOR DAMAGES

" 1 101. Dr. Omalu says that the' brain darnage he found in four ex-players who died is _the2 same condition found in punch-drunk boxers.3 102. Around the same time, researchers without NFL ties surveyed retired football players4 and their findings showed that players who.had multiple concussions were more likely to report5 being diagnosed with depression.6 103; Dr. Omalu questioned "Where was the NFL when we found this disease?"7 104. The NFL undertook.the responsibility of studying concussion research in 19948 through funding a Com:mittee known as the "NFL Committee on Mild Traumatic Brain Injury".9 105. The NFL Committee on Mild Traumatic Brain Injury published their findings in10 2004 showing "no evidence of worsening injury or chronic cumulative effects" from multiple11 concussions. In a related study, this Committee found many NFL players can be safely allowed t12 return to play" on the day of a concussion if they are without symptoms and cleared by a physician.13 106. As further evidence, Commissioner Roger Goodell in June 0[2007 admitted publicly14 that the NFL has been studying the effects of traumatic brain injury for close to 14 years ... ".15 107. Itwas not until June of2010 that the NFL acknowledged that concussions can lead to16 dementia, memory loss, eTE and related symptoms by publishing warning to every player and17 tearn.18 NFL'S DUTY TO PLAYERS AND THE PUBLIC19 108. The NFL overtly undertook a duty to study concussions on behalf of all American20 Rules Football leagues and players.21 109. As the industry icon, all American Rules Football leagues modeled their programs22 after the NFL.23 110. In tum, the NFL possesses monopoly power over American Football. As such, it24 also possesses monopoly power over the research and education of football injuries to physicians,25 trainers, coaches and individuals with brain damage such as Plaintiffs who played in the NFL, as26 well as the public at large. As a result, it owed a duty to everyone including individuals such as27 Plaintiffs in the following respects:28


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1 (a) Itowed a duty to protect Plaintiffs on the playing field;2 (b) Itowed a duty to Plaintiffs to educate them and other3 players in the NFL about CTE and/or concussion injury;4 (c) It owed a duty to Plaintiffs to educate trainers, physicians,5 and coaches about CTE and/or concussion injury;. 6 (d) Itowed a duty to Plaintiffs to have in place strict return-to-play7 guidelines to prevent C1E and/or concussion injury;8 (e) It owed a duty to Plaintiffs to promote a "whistleblower"9

'10111213

(f)

system where teammates would bring to the attention of atrainer, physician or coach that another player had sustainedconcussion injury;Itowed a duty to Plaintiffsto design rules and penaltiesfor players who use their head or upper body to.hit or tackle;

14 (g) Itowed a duty to Plaintiffs to design rules to eliminate the risk15 . .of concussion during games and/or practices;16 (h) It owed a duty to Plaintiffs to promote research into and171819202122

(i)

cure for eTE and the effects of concussion injury over aperiod of time; andIt owed a duty to State governments, local sports organizations, all American RulesFootbaUleagues and players, and the public at large to protect against the long-termeffects ofCTE and/or concussion injury.

23 111. The NFL knew as early as the 1920's of the harmful effects on a player's brain of24 concussions; however, until June of2010 they concealed these facts from coaches, trainers,25 players, and the public.26 112. Plaintiffs did not know the .long-term effects of concussions and relied on the NFL27 and the Riddell Defendants to protect them.28

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12 NFL'S KNOWLEDGE OF THE RISK OF CONCUSSIONS3 113. For decades, Defendants have known that multiple blows to the head can lead to

. .4 long-term brain injury, including memory loss, dementia, depression and CTE and its relat~d5 symptoms.6 114.. This action arises from the Defendants' failure to warn and protect NFL players, suchl7 as Plaintiffs against the long-term brain injury risks associated with football-related concussions.8 115. This action arises because the NFL Defendants committed negligence by failing to9 exercise its duty to enact league-wide guidelines and mandatory rules regulating post-concussion.

10 medical treatment and return-to-play standards for players who suffer a concussion and/or multiple11 concuss ions .12 116. By failing to exercise its duty to enact reasonable and prudent rules to protect players13 against the risks associated with repeated brain trauma; the NFL's failure to exercise its14 independent duty has led to the deaths of some, and brain injuries of many other former players, ..15 including Plaintiffs.16 117. The following information, which is by no means comprehensive. was available and17 easily accessible to Defendants:

(a) In the 1890's, Admiral Joseph Mason "Bull" Reeves, who is moreknown as the father of carrier aviation, played American football in the1890's for the Naval Academy. He had suffered so many blows to hishead that a navy doctor advised him that he could risk death orinsanityif he received another kick to his head.

(b) In 1913, Glenn "Pop" Warner, commented that he had "many timesseen cases when hard bumps on the head so dazed the playerreceiving them that he lost his memory for a time and had t o beremoved from the game.";

(c) In 1928, the first case o("Punch Drunk" in boxers was published-14-

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1 in the American Association Journal by HS Martland;2 (d) A 1937 article on "Dementia puglisistica" was published in the3 USNavy Medical Bulletin;4 (e) A 1952 article on "Electroencephalographic changes inprofessional5 boxers was published in the American Medical Association6 Journal; "7 (0 A 1952 New England Journal of Medicine Article Vol. 246, pp.8 554-556 talked about a three strike rule for concussions in 19459 - three concussions and you should retire from football;

10 (g) A 1954 article on "Observations on the clinical and brain wave11 patterns of professional boxers" was published in the American12 Medical Association Journal;13 (h) A 1956 article on "Diffuse degeneration of the cerebral white14 matter in severe dementia following head injury" was published15 in the Neurological, Neurosurgery and Psychiatry Journal;16 (i) A 1957 article on the "Medical aspects of boxing, particularly17 from a neurological standpoint" was published in the British18 Medical Journal;19 G) A 1959 article on the "Observations of the pathology of insidious20 dementia following head injury" was published in the Journal of21 Mental Science;22 (k) A 1966 article on "Concussion amnesia" in Neurology;23 (1 ) A 1968 article on "brains of boxers" published in Neurochirurgia;24 (m) A 1969 report by the Royal College of Physicians of London25 confirmed the danger of chronic brain damage occurring in boxers26 as a result of their careers;27 (n) " A 1969 article on "Organic psychosyndromes due boxing" in the~~~~ 28"~.J) -15-"~ "fo '

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1 British Journal of Psychiatry;2 . (0) A 1969 book on "Brain damage in boxers -A study of the prevalence3 of traumatic encephalopathy among ex-professional boxers" by AH4 Roberts;5 (p) A 1970 article on retrograde memory immediately after concussion"6 published in the Lancet;7 (q) In 1973, a disabling and sometimes deadly condition involving8 the second impact concussion occurring before symptoms of a first9 concussion was described by RC. Schneider. This later was coined

10 the Second Impact Syndrome in 1984;.11 (r) A 1973 article on 'The aftermath of boxing" published inPsychology12 Medicine;13 (s) JA Corsellis, CJ Bruton, D Freeman-Browne, The Aftermath of Boxing,14 3 Psych. Med. 270-303 (1973);15 (t) . A1974 article on "Cerebral concussion and traumatic unconsciousness,16 Correlation of experimental and clinical observations of blunt head17 injuries" published in Brain;18 (u) A 1974 article on "Traumatic encephalopathy in a young boxer"19 published in the Lancet;20 (v) A 1974 article on "Delayed recovery after mild head injury" was21 published in the Lancet;22 (w) A 1975 article on "cumulative effect of concussion" was published23 in th e Lancet;24 (x) . J . A. Corsellis, Brain Damage in Sport, 1 LANCET 401,401 (1976)25 (finding that the brain tissue of fifteen former boxers who sustained26 multiple head trauma evidenced neuropathological signs of CTE);27 (y) A 1978 article on "Posttraumatic dementia" published in Aging;~p~J 28. . . .~~ -16-"\I '. . .

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1 (z) J.C. Maroon, P.B. Steele, R. Berlin, Football Head &Neck Injuries2 - An Update, 27 Clin. Nurosurg, 414-29 (1980);3 (aa) A 1981 article on "Association football injuries to the brain: a4 preliminary report" published in the British Journal 0/ Sports5 Medicine;6 (bb) H Hugenholtz, MT Richard, Return to Athletic Competition Following7 Concussion, 127(9) Can. Med. Assoc. J. 827-29 (1982);8 (cc) RC Cantu, Guidelines to Return to Contact After Cerebral Concussion, .9 14 The Physician and Sports Medicine 75-83 (1986);

10 -(dd) Daniel N. Kulund, The Injured Athlete 269 (1988). A boxer may be11 knocked unconscious by the pam of a shot to the eye or neck during a12 match. See id. Furthermore, a blow to the heart or solar plexus may block13 the flow of blood and render the fighter unconscious. Any punches to the14 temporal region may lead to a loss of balance or dizziness;15 (ee) lA Corsellis, Boxing and the Brain, 298 BMJ 105-109 (1989);16 (ft) James P. Kelly et a1., Concussion in Sports, Guidelines/or the Prevention17 of Catastrophic Outcome, 266 JAMA 2868 (1991);18 (gg) B.E. Leininger & 1.S. Kreutzer, Neuropsychological Outcome of Adults19 with Mild Traumatic BrainInjury: Implications/or Clinical Practice and20 Research, in REHABILITATION OF POST-CONCUSSIVE DISORDERS21 (L.1. Hom & N.D. Zasler eds., State of the Art Reviews, Physical Medicine22 and Rehabilitation, Hanley &Belfus, Inc. 1992);23 (hh) RC Cantu, Cerebral Concussion in Sports, 14(1) Sports Med. 64-74 (1992);24 (ii) RC Cantu, FO Mueller, Catastrophic Football Injuries in the USA, 2(3)25 Clin. J. Sports Med. 180-85 (1992); and26 (jj) . Mild Traumatic Brain Injury Cominittee of the Head Injury Interdisciplinary27 Special Interest Group of the American Congress of Rehabilitation Medicine,e iI~J 28I \o ,~",0 -17-"I~'r-



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1 Definition of Mild Traumatic Injury, 81 . HEA D TRAU MA REHAB IL . 86-872 (1993).3 '1 1 8 . In additio n, the N FL 's du ty to pro tec t the hea lth and safety o f its p layers is fu rther4 undersco red by the irre fu tab le ev idence that the N FL has prev io usly enacted the fo llo wing no n-5 ex haustive list o f ru les perta in ing to p layers ' hea lth and safe ty :6 (a) In 1956, the N FL enac ted a ru le that p ro hib ited the grabb ing o f any player's7 facem ask , o ther than the ba ll carrie r;

(b ) In 1962, th e 'N FL en ac ted a ru le th at p ro hib ited p layers fro m g rab bin g an y p layer 'sfacemask;

(c ) In 1976, the N FL enacted a ru le that p ro hib ited p layers fro m grabb ing the facem asko f an o ppo nen t. The penalty fo r an inc iden tal g rasp o f the facem ask w as 5 yards.T he penalty fo r tw isting , tu rn ing , o r pu lling the facem ask w as 15 yards. A playerco uld be e jected fro m the gam e if the fo ul is judged to be v icio us and /o r flagran t;

(d) ' In 1977, the N FL enacted a ru le that p ro hib ited p layers fro m slapp ing the head o fano ther p layer during p lay . This ru le w as referred to as the "D eaco n Jo nes R ule",nam ed after the R am s' d efensive end w ho frequen tly used th is techn ique;

(e ) In 1977, the N FL enacted a ru le tha t p ro hib ited O ffensive L inem en fro mthrusting their hands in to a defender's neck , face , o r h ead ;

(f) In 1 979 , the N FL enacted a ru le tha t p ro hib ited p layers fro m using the ir helm ets tobu tt, spear, o r ram an o ppo nen t. Pursuan t ~ o th is ru le, any player w ho used the cro wno r the to p o f h is he lm et unnecessarily w ill be called fo r unnecessary ro ughness;

(g ) In 1 980 , the N FL enacted ru le changes tha t p ro vided greate r restrictio ns o n co ntact inthe area o f the head , neck , and face;

(h ) In 1 980 , th e N FL en acted ru le ch an ges th at p ro hib ited p layers fro m d irectly strik in g,sw ing ing , o r clubb ing the head , neck , o r face ("perso nal fo ul"). B eg inn ing in 1 980 , apenalty co uld be called fo r such co ntac t w hether o r no t the in itia l co ntac t w as m adebelo w the neck area ;

89

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1234S6789101112131415161718192021222324252627~~. . . 28",.~,p~;I" ." "

. (i) In 1982,the NFL enacted a rule change by which the penalty for incidental grabbingof a facemask by a defensive team was changed from 5 yards to an automatic firstdown plus a 5 yard penalty;

(j) In 1983. the NFL enacted a rule that prohibited players from using a helmetas a weapon to strike or hit an opponent;

(k) In 1988. theNFL enacted a rule that prohibiteddefensive players from hittingquarterbacks below the waist while they are still in the pocket. (The rule wasunofficially called the "Andre Waters Rule" based upon a hit that Waters placed onLos Angeles Rams quarterback Jim Everett in 1988); and

(1 ) Following-the 2004-2005 season, the NFL's Competition Committee reviewed videoof the entire season and concluded that the horse-collar tackle resulted in six.seriousinjuries. On May 23. 2005, the NFL owners voted 27-5 to ban the tackle. The ban.. states .that a horse-collar tackle is an open-field tackle inwhich adefender uses the.shoulder pads to immediately bring a ball carrier down.

NFL FRAUDUENfLY CONCEALED THE LONG-TERM EFFECTS OF CONCUSSIONS119. Instead of taking measures to actually protect its players from suffering long-term

brain injuries, the NFL created the "Mild Traumatic Brain Injury Committee" in 1994 to .purportedly studythe effects of concussions on NFL players.

120. . The Mild Traumatic Brain Injury Committee was chaired by Dr. Elliot Pellman, arheumatologist who is not certified as to brain injuries and/or concussions.

121. After 14 years of purported studies, and after numerous medical j oumal artic les werewritten by the NFL's Mild Traumatic Brain Injury Committee (the "NFI./s Brain InjuryCommittee H ) , concluded that" [b]ecause a significant percentage of players returned to play in thesame game [ a s they suffered ~mild traumatic brain injury] and the overwhelming majority ofplayers with concussions were kept out of football-related activities for less than 1week, it can beconcluded that mild TBl's in professional football are not serious injuries," See "Concussion in

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1 professional football: Summary of the research conducted by the National Football League's2 Committee on Mild Traumatic Brain Injury," Neu ro su rg F ocu s 21 (4):EI2, 2006, E.I. Pellman and3 D.C. Viano.4 122. According to the NFL's own committee, the speedy return to play afi:er suffering a5 concussion demonstrates that such players were not at a greater risk of suffering long-term brain6 IDJUry.7 123. The NFL-fundedstudy is completely devoid of logic and science. More importantly,8 it is contrary to their Health and Safety Rules as well as 75 years of published medical literature on9 concussions.10 124. Between 2002 and 2005, a series of clinical and neuropathological studies performed11 by independent scientists and physicians demonstrated that multiple NFL induced-concussions12 cause cognitive problems such as depression, early on-set dementia and CTE and its related13 symptoms.14 125. In response to these studies, the NFL, to further a scheme of fraud and deceit, had15 members of the NFL's Brain Injury Committee deny knowledge of a link between concussion and-16 cognitive decline and claim that more time was needed to reach a definitive conclusion on the17 issue.18 126. When the NFL's Brain Injury Committee anticipated studies that would implicate

causa11inks between concussion and cognitive degeneration it promptly published articlesproducing contrary findings, although false, distorted and deceiving as part of the NFL's scheme todeceive Congress, the players and the public at large.

127. Between 2002 and 2007, Dr. Bennet Omalu examined the brain tissue of deceasedNFL players including Mike Webster, Terry Long, Andrew Waters and Justin Strzelczyk. Dr.Omalu in an article in Neurosurgery concluded-that chronic traumatic encephalopathy ("CTE")triggered by multiple NFL concussions represented a partial cause of their deaths.

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1 128. In response to Dr. Omalu's article, the NFL acting thru the NFL's Brain Injury2 Committee, Drs. Ira Casson, Elliott Pellman and David Viano wrote a letter to the editor of3 Neurosurgery asking that Dr. Omalu's article be retracted.4 . 129. In 2005, a clinical study performed by Dr. Kevin Guskiewicz found that retired5 players who sustained three or more concussions in the NFL had a five-fold prevalence of mild6 cognitive impairment. The 'NFL's Brain Injury Committee, Dr. Mark Lowell, promptly attacked7 the article by refusing to accept a survey of 2,400 former NFL players.8 130. Because of Congressional scrutiny and media pressure, the NFL scheduled a league-9 wide Concussion Summit for June 2007. Unfortunately" the NFL in keeping with its scheme of10 fraud and deceit issued a pamphlet to players in August 2007, which stated: "there is no magic11 number for how many concussions is too many." '12 131. When Boston University's Dr. Ann McKee found CTE in the brains of two more13 deceased NFL players in 2008, Dr. Ira Casson characterized each study as an "isolated incident"14 from which no conclusion could be drawn.15 132. At the October 2009 Congressional hearings of the House Judiciary Committee,16 committee member Linda Sanchez (D-CA) analogized the NFL's denial of a causal link between17 NFL concussion and cognitive decline to the Tobacco industry's denial of the link between18 cigarette consumption and illhealth effects.19 .133. Since at least 2002, the NFL Committee has been on direct notice of multiple NFL. 20 head injuries contributing to cognitive decline in later life, yet it has never amended the 200721 NFL's Brain Injury Committee statement: "Current research with professional athletes has not22 shown that having more than one or two concussions leads to permanent problems ... It is23 important to understand that there is no magic number for how many concussions is too many."24 134. As of June 2010, the NFL had yet to amend these inaccurate and misrepresentative25 statements to any Plaintiff or retiree.2627 THE NFL ACKNOWLEDGES THEIR DUTY TO PROTECT AGAINSTTHE LONG-TERM RISK OF CONCUSSIONS

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12 135. On August 14,2007, the NFL acknowledged its duty to players by enacting rules to3 protect them against the risks associated with repeated brain trauma.4 136.. The NFL's 2007 concussion guidelines, many of which stemmed from an NFL5 conference inJune of 2007 involving team trainers and. doctors, were sent to all current players and6 other team personnel.7 137. The NFL's 2007 guidelines on concussion management include a whistle-blower8 provision for individuals to report concussions with the league so that a player with a head injury isl9 not forced to practice or play against medical advice.

10 138.. The NFL's 2007 concussion guidelines also include an informational pamphlet11 provided to all current NFL players to aid in identifying symptoms of a concussion. This .12 information was later withdrawn by one of the outside counsel of the NFL ina separate letter to its13 disability plan, as well as the NFL's August 14,2007 press release denying that "more than one or14 two concussions leads to permanent problems".15 139. In a statement issued by the NFL on August 14,2007, Roger Goodell, the16 .Commissioner of the N!L, introduced the NFL's 2007 concussion guidelines by saying, "We want17 to make sure all NFL players, coaches and staff members are fully informed and tak.~advantage of18 the most up-to-date information and resources as we continue to study the long-term impact of19 concussions."20 140. The NFL's Commissioner also stated, "[b]ecause of the unique and complex riature

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21 of the brain, our goal is to continue to have concussions managed conservatively by outstanding22 medical personnel in a way that clearly emphasizes player safety over competitive concerns."23 14~. The NFL's 2007 concussion guidelines provide when a player with a concussion can24 return to a game or practice.

142. The NFL's 2007 concussion guidelines specifically mandate that a player shouldhave no concussion symptoms and normal neurological test results before returning to play.



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1 143. For the past many decades until August 14,2007, the NFL's duty to protect its2 players has never changed and has ever waned. The only change that occurred is that on August3 14, 2007, the NFL finally and unequivocally acted upon it s longstanding duty to protect its membe. . .4 players by implementirig league-wide concussion guidelines e ,5 144. Importantly, the NFL themselves ackJ:lowledged that the 2007 guidelines were6 inadequate and insufficient. As a result, the NFL enacted more strict regulations to handle7 concussions starting in the 2009 season. Specifically, the NFL announced new rules on managing8 concussions requiring players who exhibit any significant concussion signs to be removed from a9 game or practice and be barred from returning the same day. .10 145. Nevertheless, it was not until June of2010 that the NFL warned any player of the11 long-term risks associated with multiple concussions, including dementia, memory loss, CTE and12 its related symptoms. The Riddell Defendants also failed to so warn active players untilJ3 approximately the same time frame.14 146. As of today, the NFL Defendants and the Riddell Defendants have never warned any15 Plaintiff or retired player of the long-term health effects of concussions.1617 THE DEFENDANTS' CONDUCT RISES BEYOND MERE NEGLIGENCE18 147. The aforementioned acts and omissions of the Defendants demonstrate that the19 Defendants acted with callous indifference to the rights and duties owed to Plaintiffs, all American20 Rules Football leagues and players and the public at large.21 148. The Defendants acted willfully, wantonly, egregiously, with reckless abandon, and22 with a high degree of moral culpability.2324 VERNON MAXWELL

. .25 149. PlaintiffVemon Maxwell was born on October 25, 1961 inBirmingham, Alabama.26 He lives inTempe, Arizona.27


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1 '150. Plaintiff Vernon Maxwell was drafted out of Arizona State University as a2 Linebacker. He played for the Baltimore Colts during the 1983 season and was NFL Defensive3 Rookie of the Year. During the 1984 season, he played for the Indianapolis Colts. During the4 1985-1987 seasons, he played for the Detroit Lions. During the 1989 season, he played for the5 Seattle Seahawks.6 151. Plaintiff Vernon Maxwell suffered multiple concussions that were improperly7 diagnosed and improperly treated throughout his career as a professional football player in the8 NFL.9 152. Plaintiff Vernon Maxwell was not warned by the NFL, NFL Properties, Inc., or10 Riddell Defendants of the risk oflong-term injury due to football-related concussions or that the11 league-mandated equipment did not protect him from such injury. This was a substantial factor in12 causing his current injury.13 153. Plaintiff Vernon Maxwell suffers from multiple past traumatic brain injuries with14 various symptoms including, but not limited to, memory loss. and headaches.1 516 BRODERICK "RICK" JONES17 154. Plaintiff Broderick "Rick" Jones was born on March 9, 1955 in Birmingham,18 Alabama. He lives in Birmingham. Alabama.19 155. Plaintiff Broderick "Rick" Jones played Linebacker for the Cleveland Browns from20 1977 to 1979 and for the Baltimore Colts from 1980 to 1983.21 156. Plaintiff Broderick "Rick" Jones suffered multiple concussions in the NFL that were22 improperly diagnosed and improperly treated throughout his career as a professional football playe23 in the NFL.24 157. Plaintiff Broderick "Rick" Jones was not warnedby the NFL, NFL Properties, Inc.,25 or Riddell Defendants of the risk oflong-term injury due to football-related concussions or that the26 league-mandated equipment did not protect him from such injury. This was a substantial factor in27 causing his current injury.28

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1 158. Plaintiff Broderick "Rick" Jones suffers from multiple past traumatic brain injuries'2 affecting multiple areas of his brain and causing various symptoms including, but not limited to,3 short-term memory loss.45 KENDALL and INGRID WILLIAMS6 159. Plaintiff Kendall Williams was born on February 7, 1959 in Long Beach, California.7 He is married toIngrid Williams, and they live inLas Vegas, Nevada. He has three children.8 160. Plaintiff Kendall Williams graduated from Arizona State University and played9 Defensive Back in the NFL during the 1982, 1983 and 1984 seasons for the Dallas Cowboys, the10 San Francisco 4ger's, and the Baltimorellndianapolis Colts. The Plaintiff is aware of-an NFL film11 which showed him being knocked out on the playing field during a game.12 161. Plaintiff Kendall Williams suffered multiple concussions that were improperly13 diagnosed and improperly treated throughout his career as a professional football player in the.14 NFL.15 162. Plaintiff Kendall Williams was not warned by the NFL, NFL Properties, Inc., or16 Riddell Defendants of the risk of long-term injury due to football-related concussions or that17 league-mandated equipment did not protect him from such injury. This was a substantial factor in,18 causing his current injury.

163. Plaintiff Kendall Williams suffers from multiple past traumatic brain injuriesaffecting multiple areas of his brain and causing the following symptoms including but not limitedto headaches, memory loss, difficulty reading, and sleeplessness.

MIKE C. RICHARDSON164. Plaintiff Mike C. Richardson was born onMay 23,1961 in Compton, California. He

was a second round draft pick out of Arizona State. He lives in Compton, California.

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1 165. Plaintiff Mike C. Richardson played as a Defensive Back for the Chicago Bears from2 1983;.1988 and then for the Oakland Raiders and the San Francisco 4ger's in the 1989 season. He3 won the Super Bowl in 1985 and was a NFL All-Pro in 1986.4 166. Plaintiff Mike C. Richardson suffered multiple concussions that were improperly5 diagnosed' and improperly tr~ated throughout his career as a professional football player in the6 NFL.7 167. Plaintiff Mike C. Richardson was no t warned by the NFL, NFL Properties, Inc., or8 Riddell Defendants of the riskof long-term injury due to football-related concussions or that the9 league-mandated equipment did not protect him from such injury. This was a substantial factor in

. 10 causing his current injury.11 168. Plaintiff Mike C. Richardson suffers from multiple past traumatic brain injuries12 affecting multiple areas of his brain and causing the following symptoms including but not limited'13 to depression, memory loss, poor judgment, and a history of substance abuse.1415 RENARD and VANESSA YOUNG16 169. Plaintiff Renard Young was born on July 31, 1961 in Los Angeles, California. He is17 married to Vanessa Young. They live inWinnetka, California and have two children.18 170. Plaintiff Renard Young played the 1984 season for the Kansas City Chiefs.19 Subsequently, he played briefly for the Kansas City Chiefs in the 1985 season and then as20 Defensive Back for the Seattle Seahawks in the 1987 season.21 171. Plaintiff Renard Young suffered multiple concussions that were improperly22 diagnosed and improperly treated throughout his career as a professional football player in the23 NFL.24 172. Plaintiff Renard Young was not warned by the NFL , NFL Properties, Inc., or Riddell,25 Defendants of the risk of long-term injury due to football-related concussions or that the league-26 mandated equipment did not protect him from such injury. This was a substantial factor in causing27 his current injury.28

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1 173. Plaintiff Renard Young suffers from multiple past traumatic brain injuries affecting2 multiple areas of the brain and causing the following symptoms including but not limited to .3 headaches and memory loss.45 LONZELL and LANITA HILL6 174. Plaintiff LonZell Hill was born on September 25, 1 9 65 in Stockton, California. He is7 married to Lanita Hill with two children and stepchildren. They live in Cincinnati, Ohio.. .

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8 . 175. PlaintiffLonZell Hill was drafted out of the University of Washington as a Wide9 Receiver by the New Orleans Saints. He played for the Saints during the 1 987, 1 988, 1 989 and10 1 9 9 0 seasons. While in the NFL, he had multiple concussions. He received no treatment andwas11 returned to play.12 176. PlaintiffLonZell Hill suffered multiple concussions that were improperly diagnosed13 and improperly treated throughout his career as a professional football player in the NFL.14 177 . PlaintiffLonZell Hill was not warned by the NFL, NFL Properties, Inc., or Riddell15 Defendants of the risk of long-term injury due to football-related concussions or that the league-16 mandated equipment did not protect him from such injury. This was a substantial factor in causing17 his current injury.18 178. PlaintiffLonZell Hill suffers from multiple past traumatic brain injuries affecting19 multiple areas of his brain and causing various symptoms including but not limited to severe short-20 term memory loss.2122 GEORGE AND KRISTIE VISGER23 179 . Plaintiff George Visger was born on September 26, 1 9 58 in Stockton, California. He24 is married to Kristie Visger. They live in Grass Valley, California with their two minor children25 and one step child.

180 . Plaintiff George Visger was drafted out of the University of Colorado by the N.Y.Jets in the 1980 NFL draft as a Defensive Lineman. He was released after pre-season by the N.Y.

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.e1 Jets and signed shortly into the 1980 season by the San Francisco 4get's. He played with the.4gers2 until an abrupt ending to the season after winning the 1981 Super Bowl.3 181. Plaintiff George Visger suffered multiple concussions that were improperly4 diagnosed and improperly treated during his career as a professional football player in the NFL.5 182. Plaintiff George Visger was not warned by the NFL, NFL Properties Inc., o r Riddell6 Defendants of the risk of long-term injury due to football-related concussions or that the league-7 mandated equipment did not protect him from such injury. This was a substantial factor in causing8 his current injury.9 183. Plaintiff George Visger suffers from vari?us eTE symptoms including but not10 limited to frontal and temporal lobe damage, multiple past traumatic brain injuries affecting11 multiple areas of his brain, intermittent explosive disorder, cognitive impairment, poor judgment in12 regard to finances and relationships, and early on-set dementia.1314 TERRY WRIGHT15 184. Plaintiff Terry Wright was born on July 17, 1965 inPhoenix, Arizona. Helives in16 Laven, Arizona.17 185. Plaintiff Terry Wright was a graduate of Temple University. He played two seasons. 18 for the Indianapolis Colts in 1987 and 1988. Prior to that, he was on the practice squad for the19 Cleveland Browns from1986-1987.20 . 186. Plaintiff Terry Wright suffered multiple concussions that were improperly diagnosed21 and improperly treated throughout his career as a professional football player in the NFL.22 187. Plaintiff Terry Wright was not warned by the NFL, NFL Properties, Inc., or Riddell23 Defendants of the risk of long-term injury due to football-related concussions or that the league-. 24 mandated equipment did not protect him from such injury. This was a substantial factor in causing25 his current injury.26 188. Plaintiff Terry Wright suffers from multiple past traumatic brain injuries including.27 but not limited to short-term memory loss.28

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1. 2 NEWTON WILLIAMS3 189. Plaintiff Newton Williams was born on May 10, 1959 in Charlotte, North Carolina.4 He lives in Charlotte, North Carolina.5 190.' Plaintiff Newton Williams graduated from Arizona State University. He played in6 the NFL as a Running Back. Plaintiff Newton Williams played for the San Francisco 4ger's during7 the 1982 season; played for the Baltimore Colts during the 1983 season; and then played for the8 Indianapolis.Colts during the 1984 season.9 .' 191. Plaintiff Newton Williams suffered multiple concussions that were improperly. .10 diagnosed ana improperly treated t~oughout his career as a professional player-in the NFL..11 192. Plaintiff Newton Williams was not warned by the NFL, NFL Properties, Inc., or .12 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the13 league-mandated equipment did not protect him from such injury. This was a substantial factor in14 causing his current injury .. 15 193. 'Plaintiff Newton Williams has been diagnosed with various traumatic brain injury16 symptoms including but not limited to headaches and memory loss.1718 DUANE GALLOWAY19 194. Plaintiff Duane Galloway was born on November 7, 1961 in Los Angeles, California.20 He lives in Los Angeles, California.21 195. Plaintiff Duane Galloway played in the NFL as a Cornerback for th e Detroit Lions22 from 1983 until 1987.23 196. Plaintiff Duane Galloway suffered multiple concussions that were improperly24 diagnosed and improperly treated throughout his career as a professional football player in the25 NFL.. 26 197. Plaintiff Duane Galloway was not warned by the NFL, NFL Properties, Inc., or

Riddell Defendants of the risk oflong-term injury due to football-related concussions' or that the7~~r~ 28'....~~~"" ~'-29-



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1 league-mandated equipment did not protect him from such injury. This was a substantial factor in2 causing his current injury,3 1 98 . Plaintiff Duane Galloway has been diagnosed with various traumatic brain injury4 symptoms including but not limited to headaches and memory loss.567

GEORGEandARNELLAJANnSON. .1 9 9 . Plaintiff George Jamison was born on September 30, 1 962 inBridgeton, New Jersey.8 He is married to Amella Jainison. They live in Rochester Hills, Michigan and have been married9 for l6 years. He has two children ages 13 and 14, and one step child who is 25 years old.10 200. Plaintiff George Jainison was drafted by the Detroit Lions in 1986 . Plaintiff played11 for the Lions from 1986-1993, from 1994 to 1996 for Kansas City Chiefs, and from 1997 to 199812 for the Detroit Lions. During Plaintiffs entire NFL career, he played as a Linebacker and earned13 team awards.14 401 . Plaintiff George Jamison suffered multiple concussive head injuries. His symptoms15 included light-headedness, seeing stars and losing track of time. Jamison remembers times that he16 was dazed but continued to play because no one took him out of the games. On one occasion while17 playing for the Lions, he could not remember anything other than the beginning of a single quarter.18 202. Plaintiff George Jamison suffered repeated concussions that were improperly19 diagnosed and improperly treated throughout his career as a professional football player in the20 NFL.21 . 203. Plaintiff George Jamison was not warned by the NFL, NFL Properties, Inc., or22 Riddell Defendants of the risk oflong-term injury due to football-related concussions or that the. .

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t~"J 28~~.,., 0'~\r ". . . .

23 lea~e-mandated equipment did not protect him from such injury. This was a substantial factor in24 causing his current injury.204. Plaintiff George Jamison suffers from multiple past traumatic brain injuries affecting

multiple areas of his brain which includes but is not limited to the following problems: memory-.related problems, blurred vision and constant headaches,



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12 BRYAN HOOKS3 205. Pla in tiff B ryan H ooks was bo rn o n Septem ber 1 5, 1 9 70 in T em pe, A rizo na.: H e lives4 in Tem pe, A rizo na.5 20 6. Pla in tiff B ryan H ooks played fo r N ew England during the 1 9 9 3, 1 9 9 4 and 1 9 9 56 seaso ns and fo r the A rizo na Cardinals du ring the 1 9 9 6 and 1 9 9 7 seaso n. H e played No se Tackle.7 20 6. P lain tiff B ryan Hooks suffered m ultip le co ncussio ns that were im pro perly diagno sed8 and im pro perly treated thro ugho ut his career as a pro fessio nal fo otball p layer in the NFL.9 20 7. P lain tiff B ryan Hoo ks w as no t w arned by the NFL , NFL Pro perties, Inc ., o r R iddell1 0 D efendants o f the risk o flo ng-tenn injury due to fo otball-re lated co ncussio ns o r that the league-1 1 m andated equipm ent did no t pro tect h im fro m such injury . T his w as a substantia l facto r in causing1 2 his current in jury .1 3 20 8. Pla in tiff B ryan H ooks suffers from multip le past traum atic b rain injuries affecting1 4 m ultip le areas o f his brain and includes but is no t lim ited to the fo llo wing sym pto ms: disto rted1 5 v is io n o r blurry visio n in the right eye requiring him to w ear co rrective glasses and m em ory lo ss.1617 FRED and TIA MCNEILL1 8 20 9 . P lain tiff F red M cN eill w as bo rn o n M ay 6, 1 9 52 in D urham , N orth Caro lina. H e is1 9 m arried to T ia M cN eill. They live in Lo s A ngeles, C alifo rn ia .20 21 0 . P lain tiff F red M cNeill w as drafted in the first ro und o u t o f UCLA . H e played21 L inebacker w ith the M inneso ta V ikings fro m 1 974 to 1 985 fo r tw elve seaso ns and played in tw o22 Super Bow ls.

21 1. P la in tiff F red M cN eill suffered m ultip le co ncussio ns that w ere im pro perly diag no sedand im pro perly treated thro ug ho ut his career as a pro fessio nal fo otball p layer in th e N FL .21 2. P la in tiff F red M cNeill was no t warned by the NFL , NFL Pro perties, Inc ., o r R iddell .D efend ants o f th e risk o flo ng-tenn injury due to fo otball-re lated co ncussio ns o r that the league-

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.e1 mandated equipment did not protect him from such injury. This was a substantial factor in causing2 his current injury. .3 213. Plaintiff Fred McNeill suffers from multiple past traumatic brain injuries affecting4 multiple areas of his brain causing Plaintiff to suffer from the early stages of dementia.56 REGINALD ROGERS, SR.7 214. Plaintiff Reginald Rogers, Sr. was born on January 21, 1964 in Sacramento,8 California. He lives in Seattle, Washington. He is engaged to be married to Lora Monan. He has9 six children ages 9, 11, 18,21 twins and 26.10 '215. Plaintiff Reginald Rogers, Sr. was drafted in 1987 in the first round by the Detroit11 Lions. He played Defensive End for two seasons ~ 1987 and 1988, with Buffalo in the 199112 season, and for Tampa Bay in the 1992 season.13 216. Plaintiff Reginald Rogers, Sr. suffered multiple concussions that were improperly14 diagnosed and improperly treated throughout his career as a professional football player in the15 NFL.16 217. Plaintiff Reginald Rogers, Sr. was not warned by the NFL~NFL Properties, Inc., or17 Riddell Defendants of the risk of long-term injury due,to football-related concussions or that the18 league-mandated equipment did not protect him from such injury. This was a substantial factor in19 causing his current injury.

218. Plaintiff Reginald Rogers, Sr. suffers from past traumatic brain injuries affectingmultiple areas of his brain and causing various symptoms including but not limited t o : g rand-ma lseizures, headaches, loss of hearing and sleeplessness.

MEL YIN and JA VON! JENKINS219. Plaintiff Melvin Jenkins was born on March 16, 1962 in Jackson, Mississippi. He ismarried to Javoni Jenkins. They live in Goodyear, Arizona.

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1 220. Plaintiff Melvin Jenkins was selected to play in the NFL from Cincinnati University.2 He played as aDefensive Back from 1987 to 1990. for Seattle Seahawks, 1991 to 1993 for Detroit3 Lions and 1993 for the Atlanta Falcons.4 221. Plaintiff Melvin Jenkins suffered multiple concussions that were improperly5 diagnosed and improperly treated throughout his career as a professional football player in the6 NFL.7 222 ... Plaintiff Melvin Jenkins was not warned by the NFL, NFL Properties, Inc. or Riddell. 8 Defendants of the risk of long-term injury due to football-related concussions or that the league-9 mandated equipment did not protect him from such injury. This was a substantial factor in causing10 his current injury.11 223. Plaintiff Melvin Jenkins suffers from multiple past traumatic brain injuries that12 include but are not limited to his various problems including memory loss.1314 ANTONIO and BETTY GmSON15 224. Plaintiff Antonio Gibson was born on July 5, 1962 inJackson, Mississippi. He is16 married to Betty Gibson, and they live in College Station, Texas.17 225. Plaintiff Antonio Gibson played Safety with the New Orleans Saints and Dallas18 Cowboys from 1986 to 1992.19 226. Plaintiff Antonio Gibson suffered multiple concussions that were improperly20 diagnosed and improperly treated throughout his career as a professional football player in the21 NFL.22 227. Plaintiff Antonio Gibson was not warned by the NFL, NFL Properties, Inc., or23 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the24 league-mandated equipment did not protect him from such injury. This was a substantial factor in25 causing his current injury.2627

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1 228. Plaintiff Antonio Gibson suffers from multiple past traumatic brain injuries that2 include but are not limited to his various problems including memory loss, sleeplessness and3 headaches.4'5 ALVIN and ODETfA MOORE6 229. Plaintiff Alvin Moore was born on May 3, 1959 in Randolph, Arizona.' He is married'7 to Odetta Moore. They live in Chandler, Arizona.8 230. Plaintiff Alvin Moore played Running Back with the Baltimore and Indianapolis9 Colts from 1983 to 1984, for th e Detroit Lions from 1985 to 1986, and for the Seattle Seahawks in10 1987.11 231. Plaintiff Alvin Moore suffered multiple concussions that were improperly diagnosed12 and improperly treated throughout his career as a professional football player in the NFL.13 232. Plaintiff Alvin Moore was not warned by the NFL, NFL Properties, Inc., or Riddellt'4 Defendants of the risk oflong-term injury due to football-related concussions or that the league-15 mandated equipment did not protect him from such injury. This was a substantial factor in causing16 .his current injury.17 233. Plaintiff Alvin Moore suffers from multiple past traumatic brain injuries that include18 but are not limited to his various problems including memory loss, ringing in his ears and19 headaches.2021 LYVONIA A. "STUMP" MITCHELL22 234. Plaintiff Lyvonia A. "Stump" Mitchell was born on March 15, 1959 in Kingsland,23 Georgia. He lives in Baton Rouge, Louisiana.24 235. Plaintiff Stump Mitchell played Running Back and Kick Returner for the St.25 Louis/Phoenix Cardinals from 1981 to 1989. He has accumulated over 10,000 career all-purpose26 yards.27



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1 236. Plaintiff Stump Mitchell suffered multiple concussions that were "improperly2 diagnosed and improperly treated throughout his career as a professional football player in the3 NFL.4 237. Plaintiff Stump Mitchell was not warned by the NFL, NFL Properties, Inc., or

. ..5 Riddell Defendants of the risk oflong-terrn injury due to football-related concussions or that the6 league-mandated equipment did not protect him from such injury. This was a substantial factor in7 causing his current injury.8 238. Plaintiff Stump Mitchell suffers from multiple past traumatic brain injuries including,9 but not limited to the. following: headaches, neck problems; vision problems, and occasional. .10 confusion.1112 KIRK CAMERON "K.C." JONES13 239. Plaintiff Kirk Cameron "K.C." Jones was born on March 28, 1974 inMidland, Texas.14 He lives inLantana, Florida.15 .240. Plaintiff Kirk Cameron "K.C." Jones played Center and Guard for the Denver16 Broncos from 1997 to 2002.17 241. Plaintiff Kirk Cameron "K.C." Jones suffered multiple concussions that were18 improperly diagnosed and improperly treated throughout his career as a professional football playe19 in the NFL.20 242. Plaintiff Kirk Cameron "K.C." Jones was not warned by the NFL, NFL Properties,21 Inc., or Riddell Defendants of the risk oflong-tenn injury due to football-related concussions or22 that the league-mandated equipment did not protect him from such injury. This was a substantial23 factor in causing his current injury.24 243. Plaintiff Kirk Cameron "K.C." Jones suffers from multiple past traumatic brain25 injuries that include but are not limited to his various problems including short-term memory loss,26 lethargy, headaches, and sleep-deprived anxiety.27



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.e1 JAMES E. "TOOTlE" and SHANEETAROBBINS2 244.. P lain tiff Jam es E . "To o tie" Robbins was bo rn o n June 2, 1 9 58 in W indso r, N o rth3 C aro lina. H e lives in C hand ler, A rizo na. H e is m arried to Shaneeta.4 245. P lain tiff Jam es E . "To o tie" Robbins played O ffensive Tackle fo r the S t. Lo uis and5 A rizo na Cardinals and the G reen Bay Packers from 1982 to 1 9 9 3.6 246. P lain tiff Jam es E . "To o tie" Robbins suffered m ultip le co ncussio ns that were

. .7 im pro perly diagno sed and im pro perly treated thro ugho ut his career as a p ro fe ss io n al fo o tb all p la ye8 in the N FL .9 247. Pla in tiff Jam es E . "To o tie" Robbins w as no t warned by the NFL , NFL Pro perties,'1 0 Inc., o r R iddell D efendants o f the risk o f lo ng-term injury due to fo otball-re lated co ncussio ns o r1 1 that the league-m andated equipm ent did no t pro tect h im fro m such injury . T his w as a substantial1 2 facto r inc au sin g h is c urre nt in ju ry .1 3 248. P lain tiff Jam es E . "To o tie" Robbins suffers from multip le past traum atic brain1 4 injuries that include but are no t lim ited to his.vario us pro blem s including headaches and sho rt-term15 mem o ry lo ss.1617 ROBERT J. and BARBARA FREDRICKSON1 8 249 . P lain tiff R obert J., Fredrickso n w as bo rn o n M ay 13, 1 9 71 in 81 . Jo seph, M ichigan.1 9 He lives in Paradise V alley , A rizo na. H e is married to B arbara and they have 3 children ages 1 3,920 and 7 years o ld .21 250 . P lain tiff R obert 1 . F re drick so n p la yed L in eb ac ker fo r th e L o s A ng ele s/O ak la nd22 Raiders from 19 94 to 1 9 97, the D etro it L io ns in 1 99 8, and A rizo na Cardinals fro m 1 99 9 to 20 02 .23 251 . P la in tiff R obert 1. F re dric kso n su ffe re d m ultip le c on cu ssio ns th at w ere im pro perly24 diagno sed and im pro perly treated thro ugho ut his career as a pro fessio nal fo otball p layer in the. .2S NFL.26 252: P la in tiff R obert 1 . Fredrickso n R obbins w as no t w arned by the N FL , N FL Pro perties,

Inc., o r R idd ell D efendants o f the risk o f lo ng-term in jury due to fo otball-related co ncussio ns o r7~g~~ 28' '," "o';"~I'~~I~' -36-CO MPLA IN T FOR D AM AG ES


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1 that the league-m andated equipm ent did no t pro tect h im fro m such injury . T his w as a substantial2 factor in c au sin g h is c urr en t in ju ry .3 253. P la in tiff R ob er t I. F redrick so n R ob bin s su ffers fro m m ultip le past traum atic brain4 inju ries that include but are no t lim ited to his vario us pro blem s includ ing headaches, m em ory lo ss,5 lig ht se nsitiv ity an d lo ss o f a tte ntio n sp an .6'CHARLES E. "CHUCKlE" MILLER8 254. .P lain tiff C ha rle s E . "Chuckle" M iller was bo rn o n M ay 9, 1965 i n Ann is ton ,9 A labam a. H e lives in Signal H ill, Califo rn ia . H e has 4 children ages 7 m onths, 7 , 19 and 21 years10 old .11 255. P lain tiff C ha rles E . "Chuckle" M iller p lay ed C ornerback fo r the Indianapo lis C olts12 from 1987 to 1989.13 256. P lain tiff C harles E . "C huckie" M iller suffered m ultip le co ncussio ns that w ere14 im pro perly diagno sed and im pro perly treated thro ugho ut his career as a p ro fe ssio nal fo o tb all p lay e15 in th e NFL.16 257. P la in ti ff Cha rle s E. "Chuckie" M iller w as no t w arned by the N FL , N FL Pro perties,1 7 Inc., o r R iddell D efendants o f the risk o f lo ng-term injury due to fo otball-rela ted co ncussio ns o r18 that the league-m andated equ ipm ent did no t pro tect h im fro m such in jury . T his w as a substantia l19 factor in c au sin g h is c urre nt in ju ry .20 258. P lain tiff C ha rle s E . "Chuckie" M iller su ffers from m ultip le p ast trauma tic b ra in21 in juries that include but are no t lim ited to his vario us p ro blem s including headaches, sho rt-term22 memor y lo ss , a nd sle ep le ss ne ss .23

24 EDWARD P. and SUSAN LEE25 259. Plain tiff E dw ard P. L ee w as bo rn o n D ecem ber 8,1959 in W ashingto n , D .C . H e is26 m arried to Susan Lee. They live in B ro o kev ille , M aryland, They have three children ages 1 8, 1 227 and 9 .28 -37-

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1 260 . P la in tiff Edward P . L ee played W ide Receiver fo r the D etro it L io ns from 19 82 to2 1 9 84.3 ,261 . P la in tiff Edward P . L ee su ffered m ultip le co ncussio ns that were im pro perly4 diagno sed and im pro perly treated th ro ugho ut his career as a pro fessio nal fo otball p layer in the5 NFL.6 262. P la in tiff Edward P . Lee w as no t w arned by the NFL ; NFL Pro perties, Inc ., o r R iddell7 D efen dan ts o f th e risk o f lo ng-term injury . due t o fo o tb all-re la ted c on cu ssio ns o r th at th e lea gu e-8 m andated equipm ent did no t pro tect h im fro m such injury . T his w as a substan tial facto r in causing9 h is c urr en t in ju ry .10 263. P la in tiff E dw ard P. L ee suffers fro m multiple p ast traum atic b ra in in ju ries th at11 include bu t are no t lim ited to h is vario us pro blem s including m em ory lo ss.1213 PATRICK and SHARRON HEENAN14 . 264. P la in tiff Patrick H eenan w as bo rn o n M arch 1 ; 1 9 38 in D etro it, M ichigan. H e is1 5 m arried to Sharro n . They live in L en o ir C ity ; T en ne ss ee .16 265 . P la in tiff Patrick H eenan played C ornerback fo r the W ashing to n R edsk ins fro m 1 96017 to 1 961 .1 8 '266. P la in tiff Patrick Heenan suffered m ultip le co ncussio ns that were im pro perly1 9 diagno sed and im pro perly treated thro ugho ut his career as a pro fessio nal fo otball p layer in th e20 NFL ..21 267. P la in tiff Patrick H eenan w as no t w arned by the N FL , N FL Pro perties, Inc ., o r R iddell22 D efendan ts o f the risk o f lo ng -term injury due to fo otball-re la ted co ncussio ns o r that the league-23 m andated equipm en t did no t p ro tect h im fro m such in jury . T his w as a substan tial facto r in causing24 h is c urr en t in ju ry .25 268. P lain tiff Patrick H eenan suffers from multip le past traum atic brain injuries that26 include bu t are no t lim ited to his vario us pro blem s including sho rt-term m em ory lo ss, headaches,27 and ringing in ears.28

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123

TOBY L. WRIGHT269 . P lain tiff T o by L. W right w as bo rn o n N ovem ber 1 9,1 970 inPho enix , A rizo na. H e,

4 .lives in T em pe, A rizo na.5 270 . P la in tiff To by L. W right played S tro ng Safety fo r the Lo s A ngeles R am s in 1 99 4, fo r6 the s t . Louis R am s from . 1 99 5 to 1 9 98, and fo r the W ashingto n Redskins in 1 99 9 . H e was selected7 as an NFL A ll-P ro in 1 9 9 6.8 271 . P la in tiff Toby L.Wr ig ht su ffered m ultip le co nc ussio ns th at w ere im pro perly9 diagnosed 'and im pro perly treated thro ug ho ut his, c areer as a pro fessio nal fo o tball p layer in the10 NFL . ,',n 272. Pla in tiff To by L . W right was no t warned by the NFL , NFL Pro perties, Inc ., o r12 R iddell D efendants o f the risk o f lo ng-term injury due to fo otball-re la ted co ncussio ns o r that the13 le ag ue -m a nd ate d.e qu ipm en t d id n o t p ro te ct him fro m such injury . T his w as a substan tia l facto r in14 c au sin g h is c ur re nt in ju ry :15 2 73 . P lain tiff-T o by L . W right suffers fro m m ultip le past traum atic brain injuries that16 inclu de but are nat lim ited to his v ario us pro blem s inclu ding sho rt-term m em o ry lo ss, headaches,17 depres si on, r in g ing in e ars, an d b lu rry v isio n.1819 KELLYKIRCHBAUM20 274. P lain tiff K elly K irchbaum was bo rn o n June 1 4, 1 9 57 in Fo rt Kno x , K entucky. H e21 l ives inLex in gto n , K entu ck y.22 275. Pla in tiff K elly K irchbaum played M idd le L inebacker and Special Team s fo r the N ew23 Yo rk Jets from 1979 to 1 9 80 , fo r the Kansas C ity Chiefs in 1 9 81 , and fo r the Ph iladelphia E agles24 in 1 9 87. ..25 276. Pla iritiffK elly K irchbaum suffered m ultip le co ncussio ns that w ere im pro perly26 diagno sed and im pro perly treated thro ugho ut his.career as a pro fessio nal fo otball p layer in the27 NFL.28

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e1 277. Plaintiff Kelly Kirchbaum was not warned by the NFL, ~L Properties, Inc., or .2 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the3 league-mandated equipment did not protect him from .such injury. This was a substantial factor in4 causing his current injury.5 . .278. Plaintiff Kelly Kirchbaum suffers from multiple past traumatic brain injuries that6 include but are not limited to his various problems including from confusion, memory loss, and7 dizziness.89 JAMES and BONITA HOOD10 279. Plaintiff James Hood lives in Inglewood, California. He was born on September 9,11 1961. He is married to Bonita Hood. They have 3 children ages 23, 20 and 18 years old ...12 280. Plaintiff James Hood played Wide Receiver for the Seattle Seahawks from 1987 to13 1988.14 281. Plaintiff James Hood suffered multiple concussions that were improperly diagnosed'15 and improperly treated throughout his career as a professional football player in the NFL.16 282. Plaintiff James Hood was not warned by the NFL, NFL Properties, Inc., or Riddell _17 Defendants of the risk of long-term injury due to football-related concussions or that the league-18 mandated equipment did not protect him from such injury. This was a substantial factor in causing19 his .current injury.

283. Plaintiff James Hood suffers from multiple past traumatic brain injuries that includebut are not limited to his various problems including memory loss and headaches.

202 1222324252 627e ~~J 2 8~f'~-0"~ "f

RICHARD and YADIRA MERCIER284. Plaintiff Richard Mercier was born on May 13, 1975 in Quebec, Canada. He is

married to Yadira Mercier. They live inMiami, Florida. The have one child age 9 months.285. Plaintiff Richard Mercier played Offensive Lineman for the Baltimore Ravens,

Denver Broncos and Cleveland Browns from 2000 to 2003.-40-

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1 ,286. Plaintiff Richard Mercier sufferedmultiple concussions that were improperly2 diagnosed and improperly treated throughout his career as a professional football player in the3 NFL.4 287 . PlaintiffRichard Mercier was not warned by the NFL, NFL Properties, Inc., or5 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the6 league-mandated equipment did not protect him from such injury. This was a substantial factor in7 causing his current injury.8 288. Plaintiff Richard Mercier suffers from multiple past traumatic brain injuries that9 include but are not limited to his various problems including memory loss.

1011 BRETT and EMILY ROl.\1BERG .12 289. Plaintiff Brett Romberg was born on October 10, 1979 in Windsor, Canada. He is13 married to Emily Romberg. They live in Coral Gables, Florida.14 290. Plaintiff Brett Romberg played Center for the Jacksonville Jaguars, St. Louis Rams15 and Atlanta Falcons from 2003 to 2010.16 291. Plaintiff Brett Romberg suffered multiple concussions that were improperly17 diagnosed and improperly treated throughout his career as a professional football player in the18 NFL.19 292 . Plaintiff Brett Romberg was not warned by the NFL, NFL Properties, Inc., or Riddell20 Defendants of the risk of long-term injury due to football-related concussions or that the Ieague-21 mandated equipment did not protect him from such injury. This was a substantial factor in causing22 his current injury.

293. Plaintiff Brett Romberg suffers from multiple past traumatic brain injuries thatinclude but are not limited to his various problems including headaches.

2 32 425, 2 62 7

Gi'~ 28r~~ O.~H~~

STEVE and KARELIS KORTE

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, 1 294. Plaintiff Steve Korte was born January 15,,1960 in Denver, Colorado. He is married2 to Karelis Korte. They live in Covington, Louisiana. They have three children ages 25, 21 and 19.3 295. Plaintiff Steve Korte played Center for the New Orleans Saints from 1983 to 1990.4 296. Plaintiff Steve Korte suffered multiple concussions that were improperly diagnosed,5 and improperly treated throughout his career as a professional' football player in the NFL.6 297. Plaintiff Steve Korte was not warned by the NFL, NFL Properties, Inc., or Riddell7 Defendants of the risk of long-term injury due to football-related concussions or that the league-8 mandated equipment did not protect him from such injury. This was a substantial factor in causing9 his current injury.10 298. Plaintiff Steve Korte suffers from multiple past traumatic brain injuries that include11 but are not limited tohis various problems including depression, short-term memory loss and12 headaches.1314 JOE and LYDIA HARRIS15 299. Plaintiff Joe Harris was born on December 6, 1952 in Fayetteville, North Carolina,16 He is marriedto Lydia Harris. They live inEllenwood, Georgia.1 7 300. Plaintiff Joe Harris played Linebacker for the Los Angeles Raiders, Baltimore18 Ravens, San Francisco 4gers,.and Minnesota Vikings from 1977 to 1983.19 301. Plaintiff Joe Harris suffered multiple concussions that were improperly diagnosed20 and improperly treated throughout his career as it professional football player in the NFL.21 302. Plaintiff Joe Harris was not warned by the NFL, NFL Properties, Inc., or Riddell22 Defendants of the risk of long-term, injury due to football-related concussions or that the league-23 mandated equipment did not protect him from such injury. This was a substantial factor in causing24 his current injury.303. Plaintiff Joe Harris suffers from multiple past traumatic brain injuries that include but

are not limited to his various problems including memory loss, confusion and dementia.

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e e1 RODNEY and ANDETRIA HAMPTON2 304. Plaintiff Rodney Hampton was born on April 3, 1969 in Houston, Texas. He is3 married to Andetria Hampton. They live in Houston, Texas. They have three children ages 16, 124 and 4.5 305. Plaintiff Rodney Hampton played Running Back for the New York Giants from 19906 to 1997. He played in two Pro Bowls in 1992 and 1993 and won Super Bowl XXV.7 306. Plaintiff Rodney Hampton suffered multiple concussions that were improperly8 diagnosed and improperly treated throughout his career as a p'rofessional football player in the9 NFL.10 307. Plaintiff Rodney Hampton was not warned by the NFL, NFL Properties, Inc., or11 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the12 league-mandated equipment did not protect him from such injury. This was a substantial factor in13 causing his current injury.14 308. Plaintiff Rodney Hampton suffers from multiple past traumatic brain injuries that15 include but are not limited to his various problems including short-term memory loss and16 headaches ..1718 LEWIS D. and KATHY TILLMAN19 309. Plaintiff Lewis D. Tillman was born on April 16, 1966 in Oklahoma City, Oklahoma.20 He is married to Kathy' Tillman. They live in Madison, Mississippi. They have t w o children ages21 19 and 15.22 310. Plaintiff Lewis D. Tillman played Running Back for the New York Giants and23 Chicago Bears from 1989 to 1996.24 311. Plaintiff Lewis D. Tillman suffered multiple concussions that were improperly25 diagnosed and improperly treated throughout his career as a professional football player in the26 NFL.27~ .iJ 28jo",0'\f',-I"' -43-

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I,~: ' I I ,~ ,.. . . .

1 312. Plaintiff Lewis D. Tillman was not warned by the NFL, NFL Properties, Inc., or- .2 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the

3 league-mandated equipment did not protect him from such injury. This was a substantial factor in4 causing his current injury.5 313. Plaintiff Lewis D ..Tillman suffers from multiple past traumatic brain injuries that6 include but are not limited to his various problems including poor memory and headaches.78 LARRY and LINDA KAMINSKI9 314. Plaintiff Larry Kaminski was born on January 6, 1945 in Cleveland, Ohio. He is10 married to Linda Kaminski. They live in Poulsbo, Washington.11 315. Plaintiff Larry Kaminski played Center for the Denver Broncos from 1966 to 1973.12 316. Plaintiff Larry Kaminski suffered multiple concussions that were improperly13 diagnosed and improperly treated throughout his career as a professional football player in the14 NFL.15 317. Plaintiff Larry Kaminski was not warned by the NFL, NFL. Properties, Inc., or16 Riddell Defendants of the risk of long-term injury due to football-related concussions. or that the17 league-mandated equipment did not protect him from such injury. This was a substantial factor in18 causing his current injury.

318. Plaintiff Larry Kaminski suffers from multiple past traumatic brain injuries thatinclude but are not limited to his various problems including frontal temporal lobe damage,explosive mood changes, aggressiveness and depression.

DAVID and MARY LEE KOCOUREK319. Plaintiff David Kocourek was born on August 20, 1937 in Chicago, Illinois. He ismarried to Mary Lee Kocourek .. They live in Marco Island, Florida.

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1 320. Plaintiff David Kocourek played Tight End for the Los Angeles Chargers in 1960, fo2 the San Diego Giants from 1961 to 1965, for the Miami Dolphins in 1966, and for the Oakland3 Raiders from 1967 to 1968.4 321. Plaintiff David Kocourek suffered multiple concussions that were improperly5 diagnosed and improperly treated. throughout his career as a professional football player in the6 NFL.7 322. Plaintiff David Kocourek was not warned by the NFL, NFL Properties, Inc., or8 Riddell Defendants of the risk of long-term injury due to football-related concussions or that the9 league-mandated equipment did not protect him from such injury. This was a substantial factor in10 causing his current injury.11 323. Plaintiff David Kocourek suffers from multiple past traumatic brain injuries' that12 include but are not limited to his various problems including dementia.1314 ROBERT and DENISE WEATHERS15 . 324. Plaintiff Robert Weathers was bo~ on September 16, 1960 in Westfield, NY. He is16 married to Denise Weathers. They"live in Orlando, Florida.17 325. Plaintiff Robert Weathers played Running Back for the New England Patriots from18 1982 to 1988.19 326. Plaintiff Robert Weathers suffered multiple concussions that were improperly20 diagnosed and improperly treated throughout his career as a professional football player in the21 NFL.22 327. Plaintiff Robert Weathers was not warned by the NFL, NFL Properties, Inc., or23 Riddell Defendants of the risk oflong-term injury due to football-related concussions or that the24 league-mandated equipment did not protect him from such injury. This was a substantial factor in25 causing his current injury.2627

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1 328. Plaintiff Robert Weathers suffers from multiple past traumatic brain injuries that2 include but are not limited to his various problems including short-term memory loss and3 headaches.45 WAYNE and SHARON HAWKINS6 329. .Plaintiff Wayne Hawkins was born on June 17, 1938 in Fort Peck, Montana. He is7 married to Sharon Hawkins. They live in San Ramon, California.8 330 .. Plaintiff Wayne Hawkins played Right Guard for the OaklandRaiders from 1960 to. 9 1971.10 331.. Plaintiff Wayne Hawkins suffered multiple concussions that were improperly11 diagnosed and improperly treated throughout his career as a professional football player in the12 NFL.13 332. .Plaintiff Wayne Hawkins was not warned by the NFL. NFL Properties. Inc" or14 Riddell Defendants of the risk oflong-term injury due to football-related concussions or that the15 league-mandated equipment did not protect him from such injury. This was a substantial factor in16 causing his current injury.17 333. Plaintiff Wayne Hawkins suffers from multiple past traumatic brain injuries that18 include but are not limited to his various problems including dementia and myopathy.1 920 ANTHONY "TONY" BARGAIN21 334. Plaintiff Anthony "Tony" Hargain was born on December 26, 1967 in Palo Alto,22 California. He lives in Citrus Heights, California.23 335. Plaintiff Anthony "Tony" Hargain played Wide Receiver for the San Francisco24 Giants in 1991. for the Kansas City Chiefs from 1992 to 1993, for the Los Angeles Rams in 1993,25 and for the Denver Broncos in 1996.2627

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1 336. Plaintiff Anthony "To~y" Hargain suffered multiple concussions that were2 improperly diagnosed and improperly treated throughout his career as a professional football playe3 in the NFL.4 337. PlaintiffAnthony "Tony" Hargain was not warned by the NFL, NFL Properties, Inc.,5 or Riddell Defendants of the risk of long-term injury due to football-related concussions or that the6 l

Documents

Concussion Lawsuit vs. NFL