Free Affidavit - District Court of Arizona - Arizona

1 UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
2
I EADOWLARK LEMON, a married man,
3 Case Nos.: CV 04 0299 PHX DGC and
Plaintiff, CV-04-1023 PHX DGC
4
s.
5
I ARLEM GLOBETROTTERS
6 NTERNATIONAL, INC., et al.; AFFIDAVIT OF ROBERT HALL
7 Defendants.
8
I RED "CURLY" NEAL, et al.
9
Plaintiffs,
10 s.
11 I ARLEM GLOBETROTTERS
I NTERNATIONAL, INC., et al.;
12
Defendants.
13 t ARLEM cLoBETRoTTERs
NTERNATIONAL, INC., an Arizona
14 orporation,
l 5 Counter-claimant,
16 s.
17 I EADOWLARK LEMON, a married man,
Counter-defendant.
18
19 sTATE ov Miciiioaisi )
l , ) ss.
20 w/if M? coUNTY )
21
AFFIDAVIT OF ROBERT HALL
22
Robert “Showboat" Hall, being first duly sworn, states the following:
23 1. I am a Plaintiff in the above—entitled action. I submit this affidavit in support of the provided
24 Second Supplemental Disclosure pursuant to Rule 26 of the Federal Rules of Civil Procedure.
25 2. The followin facts are relevant to the issues involved in the above—entitled action.
8
26
3. l have previously produced all documents in my possession related to this dispute.
Case 2:04-cv-00299-DGC Document 394 Filed O5/O9/2006 Page 1 of 3

1 4. Recently, I located old Harlem Globetrotter documents that were in storage that contained
2 some of mv old papers:
3 Financial Report of Independent Basketball Players Association dated September 30, 1972.
4 Letter dated April 25, 1973 from Marie, Harlem Globetrotters, Inc. to Kittie Hall re: bills,
5 plane ticket, and picture used in yearbook.
6 Contract dated january 24, 1973 between Harlem Globetrotters, Inc. and Robert Hall re:
employment and television special signed by Stan Greeson.
7
8 Letter dated November 1, 1974 from Stan Greeson to Robert Hall re: several points on which
you will want information.
9 Letter dated October 14, 1974 from Harlem Globetrotters, Inc. to Robert Hall re: Harlem
IO Globetrotters, Inc. Group Health and Life Insurance Coverage for Employees—Eligibility and
Termination.
l 1
Letter dated September 20, 1974 from Stan Greeson to Bob Hall re: training camp.
l 2
Letter dated September 12, 1974 from Elliott I. Goodman to Robert Hall re: training camp.
l 3
14 Letter dated August 29, 1974 from Ira Drogin to Robert Hall re: United Basketball Players
Association.
15
Letter dated A st 29, 1974 from Elliott I. Goodman to Leon Hillard re: labor board vote.
ugu
16
Letter dated Au ust 19, 1974 from Elliott I. Goodman to Robert Hall re: Local 189 Union.
8
I 7
Tele am dated Au st 19, 1974 from ames Kem , 189 AFL—CIO, to Robert Hall re: union.
18 gr gu P
Letter dated August 6, 1974 from james Kemp, 189 AEL—CIO, to Robert Hall re: progress
19 report on Union’s activities and election.
20 Letter dated ]une 10, 1974 from Elliott I. Goodman to Members of the Independent Basketball
21 Players Association regarding upcoming "Popcorn Machine" series.
22 Letter dated April 13, 1974 from Iames Kemp, 189 AFL-CIO, to Harlem Globetrotters
Basketball Team and Harlem Globetrotters, Inc. re: authorizations signed by Harlem
23 Globetrotters basketball players and beginning contract negotiations.
24 Payroll record of Robert Hall from Harlem Globetrotters from April 1, 1974 through April 15,
2 5 1974.
26 5. These papers were not intentionally withheld and I had previously made every effort to locate
27 these papers.
28
Case 2:04-cv-00299-DGC Document 394 Filed O5/O9/2006 Page 2 of 3

l 6. All of these papers would have already been in the possession of Harlem Globetrotters, as they
2 generated most of them years ago.
3 7. I have reviewed each document and they are authentic and where my signature appears I
4 authenticated my signature.
I
8. The above facts are known by me to be true, of my own knowledge. I am competent to
6
testify to such facts, and would so testify ifI appeared in court as a witness at the trial of the matter.
7
8 FURTHER AFFIANT swam NAUGHT.
9
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oubigvzf
1 1 Robert "Showboat" Hall
12 _ . .
Subscribed an Sworn o before me this
13 Z 2 péslay of ` , 2006
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19 My C°mmissi0¤ extil:;Y
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21
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23
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28
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Case 2:04-cv-00299-DGC

Document 394

Filed 05/09/2006

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Case 2:04-cv-00299-DGC

Document 394

Filed 05/09/2006

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Case 2:04-cv-00299-DGC

Document 394

Filed 05/09/2006

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