INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

A

EXHIBIT

DOCUMENT

All

1.
or

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head

trauma

of
head

trauma

and

 INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

at

time

any
Panel

Safety
effects

of

head

trauma

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request

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17.
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the NFL

16.

the

and

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against

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15.
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information

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and

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Alleged

limited

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of the NFL,

13.
for

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at the

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on

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Documents

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was

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and

Safety

current

Injury.

weekly

to the NFL.

injury

reports

or

 INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

All

20.
or other
and/or

Alleged

football

by

sustained

by the
All

connection

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and

defense

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Communications

related

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proposals

recommendations,
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with

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in

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protocols

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players

incurred

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incurred

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settlement

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in

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the

Action.

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for

strategy

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to copies

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29.
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any
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not

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to ProCap.

32.

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relating

to the

book

33.

All

Documents

and

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relating

to the

movie

5

League

of Denial.

Concussion.

helmet

 INDEX NO. 652813/2012

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NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

All

34.
in Chicago

the

Bills

since

Communications

relating

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NFL

concussion

summit

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present.

36.
document

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19, 2007.

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through

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on June

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document

retention
storage,

and
and

destruction

electronically-stored

1950.

6

policies,

including
information,

those
maintained

relating
by

to
the

 INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

EXHIBIT

B

DEFINITIONS

The

1.

correspondence,

message,

thoughts,

whereby

to one

persons

and

or recorded

limited

databases,
books

or more

of

of any

means

directly

arising

in

any

way

embodying,

relevant

to the subject

League

Ventures,

Management

Inc.,

NFL

or

call,

discussion,

other

are transmitted

from

of,

however

or

occurrence

one

or more

or other
to"

"relate

constituting,

stored

mentioning,

in

instructions,

communications,

emails,

be reasonably

to"

or "refer

in

relating

entries

drawing,

rules,
derived

studies,
from

any

media.

reflecting,

to,

can

computer

guidelines,

letters,

not

but

including

or intra-office

reports,
that

drafts,

drafts,

inter-office

things

graphic,

communications,

diaries,

folders,

pamphlets,

microfiche

referring

pads,

all

limitation,

photographic,

or reproduced

contracts,

desk

tangible

photocopied,

produced

charts,

without

including,

typed,

files,

procedural

containing,

The

sort

any

conversation,

phone

documents

memoranda,

maps,

written

indirectly
out

all

calendars,

"regarding,"

phrases

or

of

printed,

written,

transmissions,

microfilm,

noting,

4.

all

and

to

correspondence,

and

operating

The

3.

meeting,

any

facsimile,

data

or character,

manuals,

lists,

database,

all

books,

facsimile

teletypes,

computer

kind

account,

notes,

and/or

refers

and

print-outs,

minutes,

telegrams,

things

computer

policies,

to

voicemail,

opinions,

agreements,

insurance

e-mail,

"Document"

tangible

all

refers

persons.

term

material

to

letter,

questions,

The

2.

electronic

"Communication(s)"

term

or any

representing,

any

studying,

of these

supporting,

to,

way

variations

stating,

analyzing,

terms

contradicting,

describing,

discussing,

recording,
or

evaluating

matter.

term

"NFL"

Council,

Ventures,

LLC,

means

the

the

NFL

League

NFL

Productions,

L.P.,

National

7

Football

Office,

the

LLC,

League,

the

Commissioner

NFL

National

of the

Enterprises,

Football

NFL,

LLC,

NFL
NFL

 INDEX NO. 652813/2012

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NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

their

The

5.

and

Injury
limited

Panel

Elliot

Pellman,

used

M.D.,

in these

Spine

thereof,

M.D.,

The

Committee

past

Mitchel

Burruss,

Feuer,

M.D.,

John

Richard

M.D.,

Hecht,

M.D.,

Ph.D.,

M.D.,

Frank

M.D.,

Joseph

Russell

A.,

Pintar,

Skiba,

of

any

including

A.

Stanley

Lonser,

Erik

E.

but

not

Committee"

limited

Hunt

Bates,

Randal

M.D.,

Kevin

Guskiewicz,

Margot

Swartz,

M.D.,

Thom

Merril

Mayer,

Putukian,

Ph.D.,

F.

Batjer,

Joel

Michael

Ph.D.,

Kramer,

McCrea,

the

shall

F.

Neck

Head,
and

all

be

Ron

members

Henry

M.D.,

Harbaugh,

Ph.D.,

Robert

T.

M.D.,

Courson,

Psy.D.,

and

Ellenbogen,

Boeve,

Ph.D.,

M.D.,

M.D.

means

Richard

Robert

Radovitzky,

Waeckerle,

any

Bradley

Ching,

not

Ph.D.,

and

NFL's

M.D.,

M.D.,

but

as possible.

and

Ph.D.,

Raul

M.D.,

8

P.

Hoge,

M.D.,

Joseph

the

the

Naidich,
above

or

and

Lovell,

member,

in scope

means

Ph.D.,

Herring,

as defined

broad

successor

including,

Thomas

individual

Injury

below)

Mark

and

thereunder

to,

Ernest

Barnes,

M.D.,

Ph.D.,

and

M.D.,

Butman,

Glicklich,

an

defined

M.D.,

M.D.,

or

Brain

any

thereof

members

Viano,

subcommittees

all

directors,

Traumatic

(as

Committee"

"MTBI

Spine

and

Ronald

M.D.,

all

David

members

and

corporations,

officers,

thereunder,

Committee

and

to be as inclusive

Neck

includes

Spine

any

or

former

Mild

NFL's

Morgenlander,

term

any

Requests

"Head,

present,

Berger,

Pepper

Andrew

term

and

and

subset

Document

Joel

the

Requests,

the

M.D.,

Casson,

M.D.,

Feuer,

any

and

and

as well

successors,

companies

subsidiary

subcommittees

and

Neck,

below),
Ira

M.D.,

Henry

and/or

committee

6.

defined

Document

in these

construed

(as

Head,

all

and

and

behalf.

means

any

predecessors

present

on their

acting

includes

the

or

and

Committee"

and

including

Maroon,

persons

other

1994

Safety

to,

Joseph

full

in

committees

parent

affiliated,

"MTBI

term

created

Committee

all

their

of

any

successors-in-interests,

and

agents,

employees,

As

or

and

LLC,

associated,

predecessors

related

International,

controlled,

owned,

any

NFL

LLC,

Properties,

Geoff

Bruce

Daniel

Ling,

Miller,

Resnick,

Watkins,

III,

 INDEX NO. 652813/2012

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M.D.,

Anthony

M.D.,

FACS,

Yates,

M.D.,

Ph.D.,

"Head,

Neck

and

of

to be as inclusive

Requests

The

7.

was

in

founded

past

members,

Casolaro,

M.D.,

Lombardo,

Safety

Panel"

and

shall

The

9.

actually

or

trauma,

including

"Doctor

term
Panel"

Safety

neurocognitive

above

As

the

the

shall

be

the

NFL's

Meaney,

full

Cantu,

M.A.,

Ph.D.,

Barry
the

Requests,
committee

construed

term

and/or

any

in

these

Document

these

full

Elliott

and

Safety

Panel

Silverstein,

Johnson,

Wojtys,

and/or

Document

any

subset

Requests

Robert

Anthony
John

Skiba,

Kurt

M.D.,

the

Requests,

term

of

any

all

M.D.,

Joseph

M.D.,

Edward

Document

M.D.,

that

and

any

M.D.,

Brown,

Robert

M.D.,

in these

and

Hershman,

Lawrence

M.D.,

committee

be construed

Injury

thereunder,

to,

M.D.,

Vogel,

in

used

means

Document

C.

Anthony
and

"Injury
members

or

to be as inclusive

and

as possible.

The

and

M.D.

York,

in these

limited

Jeff

Ph.D.,

Robert

M.D.,

not

Coughlin,

M.D.,

David

subcommittees

Bradley,

Michael

Tucker,

John

member,

in scope

8.

Injury

Andrew

but

James

Menon,

means

all

including,

M.D.,

FACS,

means

and

Robert

M.S.,

as possible.

and

any

Collins,

as defined

an individual

broad

Bergfeld,

Vandana

and

M.D.,

includes

above

Panel"

Safety

thereof,

James

M.D.,

Spindler,

and

present

M.D.,

and

used

member,

in scope

broad

As

defined

as

M.D.,

M.D.,

Ph.D.

individual

"Injury

1993

John

M.D.,

an

and

term

and

Anderson,

Yates,

or

Zacko,

Maroon,

Siegmund,

Committee"

Spine

members

any

Joseph

Gunter

and

J. Christopher

FACP,

FACSM,

FAANS,

Myers,

subset

M.D.,

means

resulted

allegedly

those

"Alleged

term

but

impairment,

not

MTBI

on the

individuals

Brain

from

limited

Committee,

to

neurological

means

or

any

repetitive

traumatic

brain

or

injury

9

Neck

listed

specifically

Injury"

single

Head,

above

condition,
concussive

injuries

disease,

and

(mild,

Alzheimer's

Spine

in definitions

disorder

or

or

5-7.

disease

sub-concussive

moderate,

Disease,

or

Committee,

or

that

head

severe),

Parkinson's

 INDEX NO. 652813/2012

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NYSCEF DOC. NO. 535

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Disease,

Amyotrophic

dementia,

cognitive

disease

Injury"

MDL

in

fact

control

does

includes

also

Sclerosis

or

injury

impulse

sleeplessness,
or

Lateral

those

disorder,

loss,

memory
or

problems,

result

Chronic

(ALS),

headaches,

concussive

from

or

or

whether

or not

mood

disorders,
such

head

diseases

(CTE),

Encephalopathy

anxiety

subconcussive

or

disorders,

conditions,

Traumatic

condition,

trauma.

alleged

the

by

depression,

disorder,

"Alleged

Claimants

Brain

in

the

Action.

10.

LLC,

and

The

former

District

is

Court

comprised

injuries

during

"MDL

term

Players'

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 INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

RECEIVED NYSCEF: 04/25/2019

INSTRU_CTIONS

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 INDEX NO. 652813/2012

FILED: NEW YORK COUNTY CLERK 04/25/2019 02:57 PM
NYSCEF DOC. NO. 535

respond

RECEIVED NYSCEF: 04/25/2019

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