04/27/2008 16:48 FAX 407 425 8171 MORGAN & MORGAN.PA @002
1 UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
2
l EADOWLARK LEMON, a married man, {
3 , Case Nos.: CV D4 0299 PHX DGC and
Plaimiff, ` CV -04-1023 PHX DGC
4
s.
5
u - * EM GLOBETROTTERS
6 e NTERNATIONAL, INC., et al.; AFFIDAVIT OF MARQUES I-IAYNES
7 Defendants. ,
8 I
l RED “CURLY" NEAL, et al. 1
9
Plaintiffs, I
10 . {
ll l · ‘ EM GLOBETROTTERS
l NTERNATIONAL, INC., et al.;
12
De endants.
13 » ~ · EM cLoBm*11o·r·re1zs
INTERNATIONAL, INC., an Arizona
14 orporation,
1 5 Coumenclaimaut,
16 s'
U · EADOWLARK LEMON, a married man,
8 Counter-defendant.
1
19 STATE OF TEXAS )
) ss.
20 comm? 3
21 Aggtgagtr gp Méggygs m;_N;s
22 Marques Haynes, being Earst duly swom, states the following;
23 1. I am a Plaintiff in the above~entitled action. I submit this afddavit in support of the provided
24 Second Supplemental Disclosure pursuant to Rule 26 ofthe Federal Rules of Civil Procedure.
25 2. The following facts are relevant to thc issues involved in the ubove~entitled acucm.
26
3. I have prewously produced all documents in my possession related to this dispute.
Case 2:04-cv-00299-DGC Document 398 Filed O5/O9/2006 Page 1 of 2
04/27/2006 16:48 FAX 407 425 8171 MORGAN & }{ORGAN,PA @003
1 4. Recently, around March 30, 2006, my wife found several documents that I had misplaced;
2 Letter dated August 16, 2003 from Been Green to Marques Haynes with attachments of old
articles (five news clips entitled: 1. Trotters Mcet Savidge, Alpine Fives Tonight; 2. Colorful
3 Harlem Hoopmaniacs Open Visit at Garden Tonight; 3. Sport Rays by Hal Straight; 4. The
4 Timer. . .H2.s the Last. . .; and 5. Harlem Hoopers Still Have Their Class And Hokum) with Abe
Sapcrstein, former President and Owner of the Harlem Globetrotters.
5
5. These papers were not intentionally withheld and I had previously made every effort to locate
6
all papus.
7
8 6. The above facts are known by me to be true, of my own knowledge. I am competent to
9 testify co such facts, and would so testify if I appeared in court as a witness at the trial of the matter.
10 FURTHER AFFIANT sAY ETH NAUGHT.
1 1
12
1 3
Marques aynes
I4
Subs "bed an Sworn to before me this
I5 , 2006.
I6
17
18 No Public, te of Texas
My ommission [le-/5"*=*Z007
1 9
20 REVA J. BARTLETT
Notary Public, State 0i Texas
21 My Comm. Exp. July 13, 2009
22
23
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25
26
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-2-
Case 2:O4—cv-00299-DGC Document 398 Filed O5/O9/2006 Page 2 of 2
Case 2:04-cv-00299-DGC
Document 398
Filed 05/09/2006
Page 1 of 2
Case 2:04-cv-00299-DGC
Document 398
Filed 05/09/2006
Page 2 of 2