Free Response - District Court of Arizona - Arizona

EXHIBIT "F"
Case 2:04-cv-00299-DGC Document 266-15 Filed 11/28/2005 Page1 of 4

u. .0- Lemuu v. nur, mu., cm au. Mll.HZ1·1'3gC `‘`` Meadowlark Lcmon, 4-12-05
- 1
&_;_ UNITED STATES DISTRICT COURT
W DISTRICT OF ARIZONA
MEADOWLARK LEMON, a married man,)
)
Plaintiff, )
) .
—vs— )No. CV O4 0299 PHX DGC
) and
HARLEM GLOBETROTTERS ) CV—04—1023 PHX DGC
INTERNATIONAL, INC., et al.; )
)
Defendants. )

FRED "CURLY" NEAL, et al., )
)
Plaintiffs, )
)
—vs— )
)
HARLEM GLOBETROTTERS )
I INTERNATIONAL, INC., et al., )
- _ )
A Defendants. )
)
HARLEM GLOBETROTTERS )
INTERNATIONAL, INC., an Arizona )
corporation, )
)
Counter—claimant, )
)
—vs— )
)
MEADOWLARK LEMON, a married man,)
)
Counterdefendant. )

DEPOSITION OF MEADOWLARK LEMON
Phoenix, Arizona
April I2, 2005
9 : O 2 A . M .
· REPORTED BY;
1 SHARRON L. MCPARTLIN
AZ ccR #50496
CA CSR #8740
BROU}Q¢$zZl(I4Id§’ED,C]2BB.[TH{PE2Q£@WY%U)29@=$§00 Filed 11/28/2005 Page 2 Of 4

In re: Lemon v. HG1, Inc., et al. Multi-Page ‘‘'‘ Meadowlark Lemon, 4-12-05
Page 238 Page 240
1 speculation on your part'? No one has told you that, or 1 pay you; they took percentages?
2 have they? 2 A. And I wasn't sure if they got percentages out
3 A. There has always been palm greasing good or 3 of this. I did say anything that I did at one point,
4 bad. There are times that players weren't making enough 4 they wanted a percentage out of it. They Wanted it, and
5 money to maintain themselves, and even Mr. Saperstein 5 it really came up when I was getting ready to do the
6 would come up to us and hand us enough money to get 6 movie, "The Fish that Ate Pittsburgh} I was told point
7 through the day. 7 blank that they wanted a percentage of this. I can't
8 Before the union, we weren't getting any per 8 remember if it was 15 or 20 percent, and I would say,
9 diem. We had to use our own money for per diem. Other 9 "No. We are not going that route."
10 than when we went abroad, we got $5 a day which wasn't 10 Q. In your book, you said you did a lot of
11 barely -- which wasn't enough to eat on, but we had to 11 appearances on the side. What did you mean "on the
12 put our money into it, or we had to -- in places like 12 side"?
13 England, we got free breakfast. We made use of getting 13 A. I did appearances for the Globetrotters, not
14 the free breakfast. When we played at night if it was 14 for me. I would ·- I Would ·· if We were having a bad
15 outdoors, they had sandwiches there that we would get. 15 night of bad ticket sales, if it was 200 or 300 miles
16 We would take some of them back to our room because we 16 away, they would either pick up a car for me to leave
17 weren't getting enough money to eat on. 17 from the game and drive to the next city so I could get
18 Q. So the union's primary gain through all of 18 the -- do tl1e publicity and marketing for the drive by
19 this was more per diem? 19 on the next moming on radio, television and newspaper
20 A. Not only that, my salary, and after Marques 20 and whatever it took. That's what I meant by that.
21 Haynes and I were relieved of our jobs, and they saw 21 Q. Is there anything in any contract you have
22 that they could get away with that, then they got away 22 signed with the Globetrotters that said that they would
23 with the whole union. They used certain players from 23 get a percentage of everything that you earn?
24 what I understand to get rid of the union. That's why 24 A. There is nothing in a contract that says that
25 there is no union today. 25 that I can remember, but this was what was told to me by
Page 239 Page 241
1 Q. Well, since you described yourself as an 1 the people that was in charge.
2 organization man who benefitted from the turmoil, are 2 Q. One of those people was your agent,
3 you suggesting that you had no role in the destruction 3 Mr. Greeson?
4 of the union? 4 A. Who was no longer my agent at the time.
5 A. I had no role in the destruction of the 5 Q. At one point, he told you that?
6 union. I was gone. I wasn't even there. 6 A. That was told to me at one point, yes.
7 Q. In 1977, were you there? ’ 7 Q. When you, if you did, do you recall using the
8 A. I was there in '77. I was not there when 8 Uniroyal shoes?
9 they got —- when they got rid of the union. That was 9 A. I can't remember that Uniroyal, what brand
10 after, after I had gone. 10 that was.
11 Q. In the Uniroyal letter that Mr. Townsend 11 Q. And would they have you in your uniform as
12 handed you, there is a provision that you should be 12 well if they used a picture?
13 paid. Vlfho is to pay you? Was it Uniroyal or the Harlem 13 A. I can't remember that.
14 Globetrotters? 14 Q. As part of the promotions, would it be fair
15 A. I don't know. 15 to say you were always in a Harlem Globetrotters uniform
16 Q. If you look at N0. 8(a), "In consideration 16 so they would know immediately the brand that they were
17 for player's providing the aforementioned services 17 talking about?
18 during the initial term hereof, Uniroyal will pay player 18 A. No. Not always.
19 the sum of $l,O00." 19 Q. Can you cite an example of where you were
20 A. I don't know if that came from Uniroyal or if 2O featured by a company, and you were not in your Harlem
21 it came from the Globetrotters. 21 Globetrotters uniform?
22 Q. Well, did it say in there Globetrotters, or 22 A. Not offhand right now, but I am sure there
23 did it say Uniroyal? 23 were some things that I did that probably I didn't even
24 A. It says Uniroyal in paragraph 8(c). 24 get paid for it that I didn't have a uniform on.
25 Q. Your testimony was the Globetrotters did not 25 Q. Did you ever see any items of clothing or
Brrrswe¤
254
FQ; 1 STATE OF ARIZONA )
U 2 COUNTY OF MARICOPA i
3
4 BE IT KNOWN that the foregoing deposition was
5 taken before me, SHARRON L. MCPARTLIN, a Certified Court
6 Reporter in and for the State of Arizona; that the
7 witness before testifying was duly sworn by me to
8 testify to the whole truth; that the witness will read
9 and sign the deposition; that pursuant to request,
10 notification was provided that the deposition is
11 available for review and signature; that the questions
12 propounded to the witness and the answers of the witness
R 13 thereto were taken down by me in shorthand and
14 thereafter reduced to print by computer—aided
15 transcription under my direction; that the foregoing 253
16 pages are a true and correct transcript of all
17 proceedings had upon the taking of said deposition, all
18 done to the best of my skill and ability.
19 I FURTHER CERTIFY that I am in no way related
20 to any of the parties hereto, nor am I in any way
21 interested in the outcome hereof.
22 DATED at Phoenix, Arizona, this 25th day of
23 April, 2005.
24 // ·¤ ,/7
2 5 _ N`% £`_—
AZ CCR #50496
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