Flores v. National Football League

None

COMPLAINT against Denver Broncos, John Doe Teams 1 through 29, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League. (Filing Fee $ 402.00, Receipt Number ANYSDC-25668130)Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 02/01/2022)

CIVIL COVER SHEET filed..(Wigdor, Douglas) (Entered: 02/01/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to The National Football League, re: 1 Complaint,. Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 02/01/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to New York Football Giants, Inc., re: 1 Complaint,. Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 02/01/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Miami Dolphins, Ltd., re: 1 Complaint,. Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 02/01/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Denver Broncos, re: 1 Complaint,. Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 02/01/2022)

NOTICE OF APPEARANCE by Michael John Willemin on behalf of Brian Flores..(Willemin, Michael) (Entered: 02/01/2022)

NOTICE OF APPEARANCE by David Evan Gottlieb on behalf of Brian Flores..(Gottlieb, David) (Entered: 02/01/2022)

ELECTRONIC SUMMONS ISSUED as to The National Football League. (sj) (Entered: 02/02/2022)

ELECTRONIC SUMMONS ISSUED as to New York Football Giants, Inc.. (sj) (Entered: 02/02/2022)

ELECTRONIC SUMMONS ISSUED as to Miami Dolphins, Ltd.. (sj) (Entered: 02/02/2022)

ELECTRONIC SUMMONS ISSUED as to Denver Broncos. (sj) (Entered: 02/02/2022)

NOTICE OF INITIAL PRETRIAL CONFERENCE: At the scheduled time, counsel for all parties should call 888-363-4749, Access code 3121171#, Security code 0871. Initial Conference set for 3/18/2022 at 03:00 PM before Judge Valerie E. Caproni. (Signed by Judge Valerie E. Caproni on 2/2/2022) (tg) (Entered: 02/02/2022)

Magistrate Judge Sarah L. Cave is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (sj)

Case Designated ECF. (sj)

Case Designated ECF

Case Opening Initial Assignment Notice

Case Designation

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Valerie E. Caproni. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(sj)

NOTICE OF APPEARANCE by Brad Scott Karp on behalf of Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League..(Karp, Brad) (Entered: 02/24/2022)

NOTICE OF APPEARANCE by Loretta Lynch on behalf of Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League..(Lynch, Loretta) (Entered: 02/24/2022)

NOTICE OF APPEARANCE by Lynn Beth Bayard on behalf of Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League..(Bayard, Lynn) (Entered: 02/24/2022)

NOTICE OF APPEARANCE by Brette Morgan Tannenbaum on behalf of Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League..(Tannenbaum, Brette) (Entered: 02/24/2022)

LETTER MOTION for Extension of Time to File Answer or Otherwise Respond to the Complaint addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated February 24, 2022. Document filed by Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League..(Lynch, Loretta) (Entered: 02/24/2022)

ORDER: granting 18 Letter Motion for Extension of Time to File. Application GRANTED. SO ORDERED. (Signed by Judge Valerie E. Caproni on 2/24/2022) (ama) (Entered: 02/24/2022)

Set/Reset Deadlines

Set/Reset Deadlines: Denver Broncos answer due 4/11/2022; Miami Dolphins, Ltd. answer due 4/11/2022; New York Football Giants, Inc. answer due 4/11/2022; The National Football League answer due 4/11/2022. (ama)

JOINT LETTER MOTION to Adjourn Conference addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated March 4, 2022. Document filed by Brian Flores..(Wigdor, Douglas) (Entered: 03/04/2022)

ORDER granting 20 Letter Motion to Adjourn Conference. Application GRANTED. The initial pretrial conference, currently scheduled for Friday, March 18, 2022 at 3:00 P.M., is adjourned to Friday, April 29, 2022 at 11:00 A.M. Pre-conference submissions are due no later than Thursday, April 21, 2022. For a description of the pre-conference submission requirements, the parties should consult the Court's Order at docket entry 13. The Court will decide whether to hold the conference in person or by teleconference once the Court has reviewed the parties' pre-conference submissions. Any amended complaint is due no later than Friday, April 8, 2022. After an amended complaint has been served on Defendants or they waive such service, the parties may file a joint stipulation for the Court's approval with a proposed deadline for Defendants to answer, move, or otherwise respond to the Amended Complaint. SO ORDERED. Initial Conference set for 4/29/2022 at 11:00 AM before Judge Valerie E. Caproni.. (Signed by Judge Valerie E. Caproni on 3/4/2022) (tg) (Entered: 03/04/2022)

Set/Reset Deadlines

Set/Reset Deadlines: Amended Pleadings due by 4/8/2022. (tg)

FIRST AMENDED COMPLAINT amending 1 Complaint, against Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League, Houston NFL Holdings, L.P., Arizona Cardinals Football Club LLC, Tennessee Titans Entertainment, Inc., John Doe Teams 1 through 26 with JURY DEMAND.Document filed by Brian Flores, Steve Wilks, Ray Horton. Related document: 1 Complaint,..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Houston NFL Holdings, L.P., re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Tennessee Titans Entertainment, Inc., re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Arizona Cardinals Football Club LLC, re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

Summons Issued

Summons Issued

Summons Issued

FIRST AMENDED COMPLAINT amending 1 Complaint, against Denver Broncos, Miami Dolphins, Ltd., New York Football Giants, Inc., The National Football League, Houston NFL Holdings, L.P., Arizona Cardinals Football Club LLC, Tennessee Titans Entertainment, Inc., John Doe Teams 1 through 26 with JURY DEMAND.Document filed by Brian Flores, Steve Wilks, Ray Horton. Related document: 1 Complaint,..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Houston NFL Holdings, L.P., re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Tennessee Titans Entertainment, Inc., re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

REQUEST FOR ISSUANCE OF SUMMONS as to Arizona Cardinals Football Club LLC, re: 22 Amended Complaint,. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 04/07/2022)

ELECTRONIC SUMMONS ISSUED as to Houston NFL Holdings, L.P...(pc) (Entered: 04/07/2022)

ELECTRONIC SUMMONS ISSUED as to Tennessee Titans Entertainment, Inc...(pc) (Entered: 04/07/2022)

ELECTRONIC SUMMONS ISSUED as to Arizona Cardinals Football Club LLC..(pc) (Entered: 04/07/2022)

NOTICE OF APPEARANCE by Brad Scott Karp on behalf of Arizona Cardinals Football Club LLC, Houston NFL Holdings, L.P., Tennessee Titans Entertainment, Inc...(Karp, Brad) (Entered: 04/18/2022)

NOTICE OF APPEARANCE by Loretta Lynch on behalf of Arizona Cardinals Football Club LLC, Houston NFL Holdings, L.P., Tennessee Titans Entertainment, Inc...(Lynch, Loretta) (Entered: 04/18/2022)

NOTICE OF APPEARANCE by Lynn Beth Bayard on behalf of Arizona Cardinals Football Club LLC, Houston NFL Holdings, L.P., Tennessee Titans Entertainment, Inc...(Bayard, Lynn) (Entered: 04/18/2022)

NOTICE OF APPEARANCE by Brette Morgan Tannenbaum on behalf of Arizona Cardinals Football Club LLC, Houston NFL Holdings, L.P., Tennessee Titans Entertainment, Inc...(Tannenbaum, Brette) (Entered: 04/18/2022)

LETTER addressed to Judge Valerie E. Caproni from Loretta Lynch dated April 18, 2022 re: Joint Stipulation and Proposed Order re Deadline for Defendants to Answer or Otherwise Respond to Amended Complaint. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League. (Attachments: # 1 Joint Stipulation and [Proposed] Order).(Lynch, Loretta) (Entered: 04/18/2022)

1 Joint Stipulation and [Proposed] Order

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JOINT STIPULATION AND ORDER: The parties, by and through their undersigned attorneys, hereby stipulate andagree as follows: The time for Defendants to answer, move or otherwise respond to theAmended Complaint shall be extended from April 21, 2022 up to and including June 21, 2022. The parties shall confer regarding the briefing schedule for any motionfiled pursuant to paragraph 1. Memoranda of law in support of and in opposition to any motion made in response to the Amended Complaint may be up to 50 pages and reply memoranda may be up to 25 pages. Nothing herein shall be deemed to constitute a waiver of any claims or defenses in this matter. (Arizona Cardinals Football Club LLC answer due 6/21/2022; Denver Broncos answer due 6/21/2022; Houston NFL Holdings, L.P. answer due 6/21/2022; Miami Dolphins, Ltd. answer due 6/21/2022; New York Football Giants, Inc. answer due 6/21/2022; Tennessee Titans Entertainment, Inc. answer due 6/21/2022; The National Football League answer due 6/21/2022.) (Signed by Judge Valerie E. Caproni on 4/18/2022) (rro) (Entered: 04/18/2022)

JOINT LETTER addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated April 21, 2022 re: Initial Pretrial Conference. Document filed by Brian Flores, Ray Horton, Steve Wilks. (Attachments: # 1 Text of Proposed Order Case Management Plan).(Wigdor, Douglas) (Entered: 04/21/2022)

1 Text of Proposed Order Case Management Plan

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NOTICE OF APPEARANCE by John Elefterakis on behalf of Brian Flores, Ray Horton, Steve Wilks..(Elefterakis, John) (Entered: 04/21/2022)

MEMO ENDORSEMENT on re: 35 Letter, filed by Brian Flores, Ray Horton, Steve Wilks. ENDORSEMENT: Due to a conflict in the Court's calendar, the initial pretrial conference, currently scheduled for Friday, April 29, 2022 at 11:00 A.M., is adjourned to Monday, May 2, 2022 at 11:00 A.M. The conference will be held in person in Courtroom 443 of the Thurgood Marshall United States Courthouse, located at 40 Foley Square, New York, New York 10007. Per the SDNY COVID-19 COURTHOUSE ENTRY PROGRAM, any person who appears at any SDNY courthouse must complete a questionnaire. Only those individuals who meet the entry requirements established by the questionnaire will be permitted entry. Additionally, any person who appears at any SDNY courthouse must comply with Standing Order M10-468 (21-MC-164), which further pertains to courthouse entry. SO ORDERED. ( Initial Conference set for 5/2/2022 at 11:00 AM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 4/21/2022) (tg) (Entered: 04/21/2022)

ORDER: IT IS HEREBY ORDERED that counsel for the parties must attend the conference in person. Any interested members of the public may attend the conference in person or remotely, by dialing 1-888-363-4749, using the access code 3121171, and the security code 0871. Recording or rebroadcasting the proceeding is strictly prohibited by law. IT IS FURTHER ORDERED that by no later than Wednesday, April 27, 2022, the parties must inform the Court how many counsel and client representatives (if any) will be attending the conference in person. Each side will be allowed four representatives at counsel table, with additional seating for the parties available in surrounding chairs and the gallery. IT IS FURTHER ORDERED that per the SDNY COVID-19 COURTHOUSE ENTRY PROGRAM, any person who appears at any SDNY courthouse must complete a questionnaire. Only those individuals who meet the entry requirements established by the questionnaire will be permitted entry. Additionally, any person who appears at any SDNY courthouse must comply with Standing Order M10-468 (21-MC-164), which further pertains to courthouse entry. SO ORDERED. (Signed by Judge Valerie E. Caproni on 4/22/2022) (tg) (Entered: 04/22/2022)

LETTER addressed to Judge Valerie E. Caproni from David E. Gottlieb dated April 27, 2022 re: Counsel Attendants for Initial Pretrial Conference. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Gottlieb, David) (Entered: 04/27/2022)

LETTER addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated April 27, 2022 re: Initial Pretrial Conference Attendees. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., John Doe Teams 1 through 26, Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 04/27/2022)

NOTICE OF APPEARANCE by Maia Usui on behalf of Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Usui, Maia) (Entered: 04/28/2022)

NOTICE OF APPEARANCE by Johnson Lassiter Atkinson on behalf of Brian Flores, Ray Horton, Steve Wilks..(Atkinson, Johnson) (Entered: 04/29/2022)

ORDER: IT IS HEREBY ORDERED that, for the reasons stated at the conference, Defendants' motion to compel arbitration is due no later than Tuesday, June 21, 2022, Plaintiffs' response in opposition is due no later than Friday, July 22, 2022, and Defendants' reply in support is due no later than Friday, August 5, 2022. The parties' briefs are limited to the default page limits: 25 pages for the opening and response briefs and 10 pages for the reply brief. If any of Plaintiffs' claims remain in the litigation following the Court's resolution of the motion, Defendants will be given the opportunity to file a motion to dismiss pursuant to Rule 12 of the Federal Rules of Civil Procedure. IT IS FURTHER ORDERED that if, upon reviewing Defendants' motion to compel arbitration, Plaintiffs still seek motion-related discovery, they must meet and confer with Defendants to determine whether the parties can resolve the issue without court intervention. If the parties are unable to resolve the dispute amongst themselves, Plaintiffs may file a letter brief, not to exceed five single-spaced pages, seeking leave to take motion-related discovery. Any such request is due no later than Friday, July 1, 2022. Any response in opposition, limited to five single-spaced pages, is due no later than Friday, July 8, 2022. IT IS FURTHER ORDERED that the entry of a Case Management Plan is adjourned sine die and fact and expert discovery is hereby STAYED. IT IS FURTHER ORDERED that if, at any time, both parties want a settlement conference with the assigned Magistrate Judge or a referral to the Court-annexed mediation program, they may submit a joint letter requesting a referral. SO ORDERED. ( Motions due by 6/21/2022., Responses due by 7/22/2022, Replies due by 8/5/2022.) (Signed by Judge Valerie E. Caproni on 5/2/2022) (tg) (Entered: 05/02/2022)

Pretrial Conference - Initial

Minute Entry for proceedings held before Judge Valerie E. Caproni: Initial Pretrial Conference held on 5/2/2022. Attorneys Douglas Wigdor, David Gottlieb, John Elefterakis and Johnson Atkinson present for the plaintiff. Attorneys Loretta Lynch, Brad Karp, Brette Tannenbaum and Maia Usui present for the defendants. Court Reporter Alena Lynch present. (anc)

TRANSCRIPT of Proceedings re: conference held on 5/2/2022 before Judge Valerie E. Caproni. Court Reporter/Transcriber: Alena Lynch, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 6/3/2022. Redacted Transcript Deadline set for 6/13/2022. Release of Transcript Restriction set for 8/11/2022..(Moya, Goretti) (Entered: 05/13/2022)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 5/2/2022 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti) (Entered: 05/13/2022)

LETTER MOTION to Seal addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated June 21, 2022. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 06/21/2022)

MOTION to Compel Arbitration and Stay Further Proceedings. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 06/21/2022)

MEMORANDUM OF LAW in Support re: 47 MOTION to Compel Arbitration and Stay Further Proceedings. . Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 06/21/2022)

DECLARATION of Dolores F. DiBella in Support re: 47 MOTION to Compel Arbitration and Stay Further Proceedings.. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League. (Attachments: # 1 Exhibit 1 (NFL Constitution and Bylaws), # 2 Exhibit 2 (Redacted Flores-Dolphins Agreement Excerpt), # 3 Exhibit 3 (Redacted Flores-Patriots Agreement Excerpt), # 4 Exhibit 4 (Redacted Flores-Steelers Agreement Excerpt), # 5 Exhibit 5 (Redacted Wilks-Cardinals Agreement Excerpt), # 6 Exhibit 6 (Redacted Wilks-Panthers Agreement Excerpt), # 7 Exhibit 7 (Redacted Horton-Titans Agreement Excerpt)).(Lynch, Loretta) (Entered: 06/21/2022)

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4

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***SELECTED PARTIES***DECLARATION of Dolores F. DiBella in Support re: 47 MOTION to Compel Arbitration and Stay Further Proceedings.. Document filed by Arizona Cardinals Football Club LLC, New York Football Giants, Inc., The National Football League, Tennessee Titans Entertainment, Inc., Miami Dolphins, Ltd., Houston NFL Holdings, L.P., Denver Broncos, Brian Flores, Ray Horton, John Doe Teams 1 through 26, Steve Wilks. (Attachments: # 1 Exhibit 1 (NFL Constitution and Bylaws), # 2 Exhibit 2 (Flores-Dolphins Agreement Excerpt), # 3 Exhibit 3 (Flores-Patriots Agreement Excerpt), # 4 Exhibit 4 (Flores-Steelers Agreement Excerpt), # 5 Exhibit 5 (Wilks-Cardinals Agreement Excerpt), # 6 Exhibit 6 (Wilks-Panthers Agreement Excerpt), # 7 Exhibit 7 (Horton-Titans Agreement Excerpt))Motion or Order to File Under Seal: 46 .(Lynch, Loretta) (Entered: 06/21/2022)

ORDER with respect to 46 Letter Motion to Seal. Plaintiffs must respond not later than Monday, June 27, 2022 why Defendants should not be permitted to file Exhibits 2 through 7 under seal. SO ORDERED. (Signed by Judge Valerie E. Caproni on 6/22/2022) (tg) (Entered: 06/22/2022)

Set/Reset Deadlines: Responses due by 6/27/2022 (tg)

Set/Reset Deadlines

LETTER RESPONSE in Opposition to Motion addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated June 27, 2022 re: 46 LETTER MOTION to Seal addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated June 21, 2022. . Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 06/27/2022)

ORDER granting 46 Letter Motion to Seal. Application GRANTED. The Court finds that employment and financial information unrelated to Defendants' arbitration agreement with Plaintiffs have a limited bearing on whether the Motion to Compel Arbitration and Stay Further Proceedings should be granted. Accordingly, the presumption of access established by Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) is accorded less weight, as access to the redacted information is not necessary to preserve the interested public's ability to monitor judicial decisionmaking. See id. at 119 ("[T]he weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power and the resultant value of such information to those monitoring the federal courts." Id. (alteration in original)). In addition, the Court finds that the privacy interests of unnamed parties included in the documents are substantial and weigh against the presumption of access. See id. at 120 (listing factors to be weighed against the presumption of access, including "the privacy interests of those resisting disclosure" (citing United States v. Amodeo, 71 F.3d 1044, 1049 (2d. Cir. 1995)). SO ORDERED. (Signed by Judge Valerie E. Caproni on 6/29/2022) (tg) (Entered: 06/29/2022)

LETTER MOTION for Discovery addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated July 1, 2022. Document filed by Brian Flores, Ray Horton, Steve Wilks. (Attachments: # 1 Exhibit A (6/24/22 Correspondence from D. Wigdor to L. Lynch), # 2 Exhibit B (6/27/22 Correspondence from L. Lynch to D. Wigdor), # 3 Exhibit C (Transcript of 5/2/22 Conference), # 4 Exhibit D (Representative Article re R. Goodell Compensation), # 5 Exhibit E (NFL Statement On Brian Flores' Suit)).(Wigdor, Douglas) (Entered: 07/01/2022)

1 Exhibit A (6/24/22 Correspondence from D. Wigdor to L. Lynch)

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2 Exhibit B (6/27/22 Correspondence from L. Lynch to D. Wigdor)

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3 Exhibit C (Transcript of 5/2/22 Conference)

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4 Exhibit D (Representative Article re R. Goodell Compensation)

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5 Exhibit E (NFL Statement On Brian Flores' Suit)

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LETTER RESPONSE in Opposition to Motion addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated July 8, 2022 re: 54 LETTER MOTION for Discovery addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated July 1, 2022. . Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 07/08/2022)

LETTER addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated July 18, 2022 re: Request For Adjournment Sine Die of Opposition Deadline. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 07/18/2022)

ORDER with respect to 47 Motion to Compel Arbitration; with respect to 54 Letter Motion for Discovery. IT IS HEREBY ORDERED that all briefing deadlines for the motion to compel arbitration are adjourned sine die until Plaintiff's request for motion-related discovery has been decided. IT IS FURTHER ORDERED that the Clerk of Court is respectfully directed to close the open motion at docket entry 56. SO ORDERED. (Signed by Judge Valerie E. Caproni on 7/18/2022) (tg) (Entered: 07/18/2022)

OPINION AND ORDER re: 54 LETTER MOTION for Discovery addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated July 1, 2022. filed by Brian Flores, Ray Horton, Steve Wilks. For the foregoing reasons, Plaintiffs' motion for discovery is DENIED. Plaintiffs' response to the motion to compel arbitration must be filed no later than Friday, August 19, 2022. Defendants' reply brief must be filed no later than Friday, August 26, 2022. ( Responses due by 8/19/2022, Replies due by 8/26/2022.) (Signed by Judge Valerie E. Caproni on 8/4/2022) (ate) (Entered: 08/04/2022)

LETTER MOTION for Extension of Time to File Response/Reply as to 47 MOTION to Compel Arbitration and Stay Further Proceedings. addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated August 9, 2022. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 08/09/2022)

ORDER granting 59 Letter Motion for Extension of Time to File Response/Reply re 59 LETTER MOTION for Extension of Time to File Response/Reply as to 47 MOTION to Compel Arbitration and Stay Further Proceedings. addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated August 9, 2022. Application GRANTED. SO ORDERED. (Signed by Judge Valerie E. Caproni on 8/9/2022) Responses due by 8/31/2022 Replies due by 9/16/2022. (ks) (Entered: 08/09/2022)

RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Fin Associates, LLC, Other Affiliate Fin 2016, LLC for Miami Dolphins, Ltd.; Corporate Parent Broncos Holdings, LLC for Denver Broncos; Corporate Parent KSA Industries, Inc. for Tennessee Titans Entertainment, Inc.. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 08/29/2022)

MEMORANDUM OF LAW in Opposition re: 47 MOTION to Compel Arbitration and Stay Further Proceedings. . Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 08/31/2022)

DECLARATION of Douglas H. Wigdor in Opposition re: 47 MOTION to Compel Arbitration and Stay Further Proceedings.. Document filed by Brian Flores, Ray Horton, Steve Wilks. (Attachments: # 1 Exhibit A - Amended Complaint, # 2 Exhibit B - NFL Statement on Brian Flores' Lawsuit, # 3 Exhibit C - Representative Article re R. Goodell, # 4 Exhibit D - Representative Article re R. Goodell, # 5 Exhibit E - Representative Article re R. Goodell, # 6 Exhibit F - Representative Article re R. Goodell, # 7 Exhibit G - Gruden v. NFL Transcript and Order, # 8 Exhibit H - Nostalgic Partners, LLC v. Yankees Order, # 9 Exhibit I - Nostalgic Partners, LLC v. Yankees Transcript, # 10 Exhibit J - McMullen Arbitration Agreement, # 11 Exhibit K - JAMS Comprehensive Arbitration Rules and Procedures, # 12 Exhibit L - JAMS Employment Arbitration Rules and Procedures, # 13 Exhibit M - JAMS Policy on Employment Arbitration Minimum Standards of Procedural Fairness).(Wigdor, Douglas) (Entered: 08/31/2022)

REPLY to Response to Motion re: 47 MOTION to Compel Arbitration and Stay Further Proceedings. . Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 09/16/2022)

LETTER MOTION for Leave to File Sur-Reply in Further Opposition to Defendants' Motion to Compel Arbitration addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated September 26, 2022. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 09/26/2022)

ORDER granting 65 Letter Motion for Leave to File Document. Application GRANTED. Plaintiffs' sur-reply, not to exceed ten double-spaced pages, is due no later than October 7, 2022. SO ORDERED. (Signed by Judge Valerie E. Caproni on 9/26/2022) (tg) (Entered: 09/26/2022)

Set/Reset Deadlines: Surreplies due by 10/7/2022. (tg)

REPLY MEMORANDUM OF LAW in Opposition re: 47 MOTION to Compel Arbitration and Stay Further Proceedings. Sur-Reply. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 10/07/2022)

LETTER addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated October 14, 2022 re: New Authority Relevant to Motion to Compel Arbitration. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 10/14/2022)

Letter

ORDER with respect to 47 Motion to Compel Arbitration. IT IS HEREBY ORDERED that by no later than February 9, 2023, Defendants must submit a supplemental brief regarding the impact of the delegation clause on the pending motion to compel arbitration. Plaintiffs' response is due by February 16, 2023. The parties' submissions must not exceed five double-spaced pages. IT IS FURTHER ORDERED that Defendants must file complete copies of the contracts attached as exhibits to the DiBella Declaration at docket entries 49 and 50 by no later than February 6, 2023. Pursuant to the Court's order at docket entry 53, Defendants may file redacted versions of the exhibits on the public docket, but the Defendants must file complete, unredacted versions of the contracts with the Court pursuant to Rule 5 the Undersigned's Individual Practices. SO ORDERED. (Signed by Judge Valerie E. Caproni on 2/1/2023) (tg) (Entered: 02/01/2023)

Set/Reset Deadlines: Motions due by 2/9/2023. Responses due by 2/16/2023 (tg)

LETTER addressed to Judge Valerie E. Caproni from Loretta E. Lynch dated February 3, 2023 re: Filing of Declaration and Exhibits. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 02/03/2023)

DECLARATION of Dolores F. DiBella in Support re: 47 MOTION to Compel Arbitration and Stay Further Proceedings.. Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League. (Attachments: # 1 Exhibit 1 - NFL Constitution and Bylaws, # 2 Exhibit 2 - Redacted Flores-Dolphins Agreement, # 3 Exhibit 3 - Redacted Flores-Patriots Agreement, # 4 Exhibit 4 - Redacted Flores-Steelers Agreement, # 5 Exhibit 5 - Redacted Wilks-Cardinals Agreement, # 6 Exhibit 6 - Redacted Wilks-Panthers Agreement, # 7 Exhibit 7 - Redacted Horton-Titans Agreement).(Lynch, Loretta) (Entered: 02/03/2023)

1 Exhibit 1 - NFL Constitution and Bylaws

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2 Exhibit 2 - Redacted Flores-Dolphins Agreement

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3 Exhibit 3 - Redacted Flores-Patriots Agreement

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4 Exhibit 4 - Redacted Flores-Steelers Agreement

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5 Exhibit 5 - Redacted Wilks-Cardinals Agreement

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6 Exhibit 6 - Redacted Wilks-Panthers Agreement

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7 Exhibit 7 - Redacted Horton-Titans Agreement

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***SELECTED PARTIES***DECLARATION of Dolores F. DiBella in Support re: 47 MOTION to Compel Arbitration and Stay Further Proceedings.. Document filed by Arizona Cardinals Football Club LLC, New York Football Giants, Inc., The National Football League, Tennessee Titans Entertainment, Inc., Miami Dolphins, Ltd., Houston NFL Holdings, L.P., Denver Broncos, Brian Flores, Ray Horton, Steve Wilks. (Attachments: # 1 Exhibit 1 - NFL Constitution and Bylaws, # 2 Exhibit 2 - Flores-Dolphins Agreement, # 3 Exhibit 3 - Flores-Patriots Agreement, # 4 Exhibit 4 - Flores-Steelers Agreement, # 5 Exhibit 5 - Wilks-Cardinals Agreement, # 6 Exhibit 6 - Wilks-Panthers Agreement, # 7 Exhibit 7 - Horton-Titans Agreement)Motion or Order to File Under Seal: 70 .(Lynch, Loretta) (Entered: 02/03/2023)

SUPPLEMENTAL RESPONSE re: 70 Order on Motion to Compel Arbitration,,, (Supplemental Brief of Defendants in Response to the Court's Order dated February 1, 2023). Document filed by Arizona Cardinals Football Club LLC, Denver Broncos, Houston NFL Holdings, L.P., Miami Dolphins, Ltd., New York Football Giants, Inc., Tennessee Titans Entertainment, Inc., The National Football League..(Lynch, Loretta) (Entered: 02/09/2023)

SUPPLEMENTAL RESPONSE re: 74 Response, . Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 02/16/2023)

OPINION AND ORDER re: 47 MOTION to Compel Arbitration and Stay Further Proceedings. filed by The National Football League, Tennessee Titans Entertainment, Inc., Denver Broncos, Arizona Cardinals Football Club LLC, Houston NFL Holdings, L.P., New York Football Giants, Inc., Miami Dolphins, Ltd.. For the foregoing reasons, Defendants' motion to compel arbitration is GRANTED except that it is DENIED as to Brian Flores's claims against the Denver Broncos, New York Giants, and the Houston Texans, and his related claims against the NFL. Defendants' request to stay the case is DENIED as to Flores's claims that may proceed to litigation and is GRANTED as to all of the claims that must be arbitrated. The Clerk of Court is respectfully directed to terminate the open motion at docket entry 47. The parties are ordered to appear for a pretrial conference on Friday, March 24, 2023, at 10:00 A.M. in Courtroom 443 of the Thurgood Marshall Courthouse, 40 Foley Square, New York, New York, 10007. By March 16, 2023, the parties must submit a joint letter regarding the status of the case, including: a. a statement of all existing deadlines, due dates, and/or cut-off dates; b. a statement describing the status of any settlement discussions and whether the parties would like a settlement conference; c. a statement of the anticipated length of trial and whether the case is to be tried to a jury; d. a statement regarding the anticipated schedule of arbitration; e. any contemplated motions; f. a proposed schedule for discovery, which must comply with the guidance set forth in the Court's model Civil Case Management Plan and Scheduling Order, available on the Court's website; g. any other issue that the parties would like to address at the pretrial conference; and h. any other information that the parties believe may assist the Court in advancing the case to settlement or trial. SO ORDERED. ( Pretrial Conference set for 3/24/2023 at 10:00 AM in Courtroom 443, 40 Centre Street, New York, NY 10007 before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 3/1/2023) (tg) (Entered: 03/01/2023)

JOINT LETTER MOTION to Adjourn Conference addressed to Judge Valerie E. Caproni from Douglas H. Wigdor dated March 3, 2023. Document filed by Brian Flores, Ray Horton, Steve Wilks..(Wigdor, Douglas) (Entered: 03/03/2023)