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Defendants:
B. The NATIONAL FOOTBALL LEAGUE, INC. (hereinafter referred to as the
“NFL”) a foreign corporation which regularly transacts business in the State of
Louisiana and within Orleans Parish whose principal place of business is located at
345 Park Avenue, New York, New York who is sued in their individual capacity
and as employers of the defendants, Roger Goodell, William Vinovich, III, Patrick
Turner and Gary Cavaletto;
C. ROGER GOODELL (hereinafter referred to as “GOODELL”), a competent
person of the age of majority who upon information and belief is domiciled in
Bronxville, New York in his capacity as the COMMISSIONER of the NATIONAL
FOOTBALL LEAGUE, INC. who upon information and belief at all times herein
was employed by the NATIONAL FOOTBALL LEAGUE, INC. who is authorized
and empowered to act as the Chief Executive on their behalf;
D. WILLIAM VINOVICH, III, (hereinafter sometimes referred to as
“VINOVICH” and/or together with defendants PATRICK TURNER and GARY
CAVALETTO collectively referred to as the subject officials) a competent person
of the age of majority who upon information and belief is domiciled at 412 Fawn
Park Circle, Council Bluffs, Iowa 51502, who at all times pertinent herein was
acting in the course and scope of his employment with the defendant, The
NATIONAL FOOTBALL LEAGUE, INC. as the Referee for the National Football
League Game between the New Orleans Saints and the Los Angeles Rams on
January 21, 2019 said game designated as the National Football Conference (NFC)
Championship game to determine the NFC representative in the NATIONAL
FOOTBALL LEAGUE, INC.’s world-wide marketed championship game known
as the “SUPER BOWL”;
E. PATRICK TURNER (hereinafter sometimes referred to as “TURNER” and/or
together with defendants WILLIAM VINOVICH, III and GARY CAVALETTO
collectively referred to as the subject officials) a competent person of the age of
majority who upon information and belief is domiciled in Lake Wood, California,
who at all times pertinent herein was acting in the course and scope of his
employment with the defendant, The NATIONAL FOOTBALL LEAGUE, INC.
as a Down Judge for the National Football League Game between the New Orleans
Saints and the Los Angeles Rams on January 21, 2019 said game designated as the
National Football Conference (NFC) Championship game to determine the NFC
representative in the NATIONAL FOOTBALL LEAGUE, INC.’s world-wide
marketed championship game known as the “SUPER BOWL”;
F. GARY CAVALETTO (hereinafter sometimes referred to as “CAVALETTO”
and/or together with defendants WILLIAM VINOVICH, III and PATRICK
TURNER collectively referred to as the subject officials) , a competent person of
Case 2:19-cv-01811-LMA-DMD Document 1 Filed 02/27/19 Page 2 of 44