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Frank Sanders v. NFL

Frank Sanders v. NFL

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Published by Paul Anderson

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Published by: Paul Anderson on Jun 04, 2012
Copyright:Attribution Non-commercial

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11/13/2013

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{Firm\5107\000\00613686.DOC}
Page 1
IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIAFRANK V. SANDERS, JOHN R.LEAKE, and ERIC HIPPLEPlaintiffs,v. NATIONAL FOOTBALL LEAGUE;and NFL PROPERTIES, LLC,Defendants.CIVIL ACTION FILE NO. ______________ JURY TRIAL DEMANDED
COMPLAINT FOR DAMAGES
The Plaintiffs hereby file this Complaint for Damages and Jury TrialDemand against the above-named Defendants, respectfully showing this Court asfollows:
INTRODUCTION
1.
 
This action is brought against Defendants the National Football League and NFL Properties, LLC (collectively, “Defendants” or “NFL”) to seek damagesrelated to Defendants’ negligence, fraud, and other misconduct regarding theserious health effects of repeated head impacts, and the injuries suffered by thePlaintiff players as a result of playing professional football in the NFL. Plaintiffs’injuries, and the significant ongoing health consequences resulting from them,include neurodegenerative disorders and diseases.
Case 1:12-cv-01905-CC Document 1 Filed 06/01/12 Page 1 of 66
 
{Firm\5107\000\00613686.DOC}
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2.
 
Until very recently, Defendants actively sought to suppress and obscure thetruth about the long-term effects of concussions and head trauma suffered while practicing and playing football for the National Football League. Defendants’efforts to obscure the truth about the cause, treatment, and consequences of football-related concussions and head trauma caused players who sufferedconcussions or head trauma to be misdiagnosed, to not receive proper treatment,and to continue practicing and playing with these severe injuries, and to befraudulently directed back on the field in spite of the severe detrimentalconsequences of the same.3.
 
As a result of Defendants’ misconduct as described herein, Plaintiffssuffered substantial injury, including economic loss. Plaintiffs hereby allege asfollows:
PARTIES
4.
 
Plaintiff Frank Sanders resides in the State of Arizona, in Phoenix, MaricopaCounty.5.
 
Plaintiff John Leake resides in the State of Texas, in Plano, Collin County.
Case 1:12-cv-01905-CC Document 1 Filed 06/01/12 Page 2 of 66
 
{Firm\5107\000\00613686.DOC}
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6.
 
Plaintiff Eric Hipple resides in the State of Michigan, in Fenton, LivingstoneCounty.7.
 
Defendant NFL is a nonprofit, non-incorporated entity organized andexisting under the laws of the State of New York, with its principal place of  business at 280 Park Ave., 15th Fl., New York, NY 10017. The NFL is not, andhas not been, the employer of Plaintiffs, who were employed by independent teamclubs during their career in professional football. The NFL regularly conducts business in, and derives substantial revenues from, Georgia.8.
 
Defendant NFL Properties, LLC, as the successor-in-interest to NationalFootball League Properties, Inc. (“NFL Properties”) is a limited liability companyorganized under the laws of the State of Delaware with its principal place of  business in the State of New York. NFL Properties is engaged in, among other activities, approving, licensing and promoting equipment by all the NFL teams.The NFL regularly conducts business in, and derives substantial revenues from,Georgia.
Case 1:12-cv-01905-CC Document 1 Filed 06/01/12 Page 3 of 66

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