This action is brought by former National Football League (“NFL” or“League”) players who seek declaratory and medical monitoring relief based on claims of negligence and fraud with respect to brain injuries caused by repeated traumatic brain and headimpacts received during the period when they were active in professional football. These claimsfor relief are brought on a classwide basis on behalf of all former NFL players who reside inCalifornia. The allegations herein, except as to the Plaintiffs, are based on information and belief.
JURISDICTION AND VENUE
Jurisdiction is based on Article 6, Section 10 of the California Constitutionand Cal. Code Civ. Pro. § 3410.10.3.
Venue in this action is proper in this Court pursuant to Cal. Code of Civ.Pro. § 395(a).
Plaintiff Cedrick Hardman (“Hardman”) resides in Laguna Beach,California. Hardman, who is now 63 years old, played in the NFL on two teams (San Francisco49ers and Oakland Raiders) from 1970-1981. He wore a Ridell helmet when he played. Mr.Hardman has experienced cognitive difficulties including headaches, dizziness, loss of memory,depression, fatigue, and sleep problems. Hardman experienced repeated and chronic head impactsduring his career in the NFL, is at increased risk of latent brain disease, and is in need of diagnosticexaminations and medical monitoring.5.
Plaintiff Tommy Mason (“Mason”) resides in Orange County, California.Mason, now 72 years old, played in the NFL on three teams (Minnesota Vikings, Los AngelesRams, and Washington Redskins) from 1961-1972. He wore a Ridell helmet when he played. Mr.Mason has experienced cognitive difficulties, including loss of memory and symptoms of