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SCHEDULE a Lemon, Et Al. V. Harlem Globetrotters International, Et Al

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SCHEDULE a Lemon, Et Al. V. Harlem Globetrotters International, Et Al SCHEDULE A Lemon, et al. v. Harlem Globetrotters International, et al. Defendants’ Objections Ex. Defendants’ Description No. Objections 1 Collective Bargaining Agreement between R HGI and UBPA (9/1/77) with attached C Player Pension Plan and Worldwide sports unsigned supplement (NSJ #2A) 2 CBA Memoranda of Agreement (8/28/80) R (modified 9/1/77 Agreement), and C amendment (NSJ #55B) 3 Collective Bargaining Agreement between N HGI and UBPA (9/1/83)(Bates #1124-1159 with signatures) and attached appendices (NSJ #2B) 4 Collective Bargaining Agreement between N HGI and UBPA (9/1/83)with attached appendices (no signatures) 5 UBPA Minutes dated 6/30/82 and 7/1/82, R and 8/16/84 and 8/17/84 U 6 Fred “Curly” Neal Contract (9/20/88) R (NSJ #3A, 74) 7 Marques Haynes Contract (10/15/75) D-1098 (NSJ #3B, 71B) 8 Robert “Showboat” Hall Contract D-1111 (10/5/73) (NSJ #3C, 75) 9 Dallas “Big D” Thornton Contract D-1130 (8/5/81) (NSJ #3D) Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 1 of 56 10 James “Twiggy” Sanders Contract of C 9/3/91 (NSJ #3E) 11 Larry “Gator” Rivers Contract (8/1/84) C (NSJ #3F, 11) 12 Letter to Fred “Curly” Neal from H Michael Syracuse (3/19/04) re: payment C Bobblehead doll promotion (NSJ #48)(Images moved to 584) 13 HGI 2002-2003 Annual Summary (NSJ #11) H (FUBU only) 14 HGI Letter to Neal (6/17/04) re: cease R & desist) H (FUBU only) C 15 Plaintiffs’ Second Request for Player R Contracts (11/25/03) H 16 Assignment and Assumption Agreement N between IBC and HGI with exhibits dated 6/7/93 signed by Paul Horton (NSJ #5A) 17 Harlem Globetrotters, Inc. Bill of Sale R to Harlem Globetrotters International, Inc. with attachments to contract and letter from Lori Vosejpka, Lindquist & Vennum to Steven Suckow, Faegre & Benson (7/8/93)cc: Theodore Nikolis (NSJ #5B) 18 Revised Harlem Globetrotters, Inc. Bill R of Sale to Harlem Globetrotters International, Inc. with exhibits (1993) and letter from Lori Vosejpka, Lindquist & Vennum to Steven Suckow, Faegre & Benson (7/21/93)(NSJ #5C) 19 Asset Purchase Agreement by and among D-187 Harlem Globetrotters International, Inc. Mannie Jackson Associates, Inc. and Harlem Globetrotters, Inc. dated 8/1/93 signed by Paul Horton (NSJ #5D) 2 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 2 of 56 20 FUBU Licensing Agreement dated 6/1/02 D-1064 and (bates 139-269)(NSJ #6) 1065, separately marked 21 Article from ESPN entitled R “Globetrotters: A Throwback Original” H with statements from Mannie Jackson (NSJ #7) 22 Mannie Jackson letter to Alumni dated D-1176 9/4/03 (NSJ #9C) 23 Plaintiffs’ demand to Mannie Jackson R dated 9/29/03 (NSJ #11) H C 24 Letters from Mannie Jackson to N Plaintiffs Thornton, Neal, Haynes dated 10/8/03 enclosing HGI FUBU Sales Report to Plaintiffs (NSJ #9A, 71C) 25 Michael Syracuse letters to Plaintiffs N dated 10-31-03 regarding FUBU payments to Plaintiffs (NSJ #9B) 26 Letter from Ed Garvey dated April 8, R 2004 enclosing purported typical player H (FUBU only) contract (NSJ #8) 27 Letter to Alumni from Mannie Jackson R (6/30/04) re: “Spinning the Globe” by H Ben Green, excerpts of index referencing Plaintiffs (NSJ #47) 28 Book “Spinning the Globe” by Ben Green R H I 29 FUBU Royalty Report (3/28/03)Faxes to R HGI D (NSJ #9D) C I 30 “Legends” Hangtags (Photo)(NSJ #12) N 3 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 3 of 56 31 Oliver Phipps Affidavits dated 11/23/05 R with Merchandise Schedules, E-Bay Sales H of Clothing (11/22/05), Letter to Neal U from Syracuse (10/31/03) with FUBU Sales Report and charts(NSJ #13A-D), and Affidavit of Oliver Phipps (5/3/06) with attachments of Plaintiffs’ Merchandise Schedule and Photograph Images 114-125(2nd Disc.) 32 FUBU Website R (NSJ #29) C 33 World of Fun--HGI Program Excerpt R (2005) (NSJ #49) H C I 34 World of Fun Program – the book R H I 35 Harvard Business review article N “Bringing a Dying Brand Back to Life” by Mannie Jackson (5/01)(NSJ #18) 36 Earl Duryea letter to Larry Gator R Rivers dated 9/10/85 (NSJ #10) H 37 Letter to Fred “Curly” Neal from HGI R dated 11/25/02 re: offer of employment H (NSJ #15) 38 Letter to Fred “Curly” Neal from Mannie R Jackson dated 7/12/93 re: HGI Letter Agreement (NSJ #16) 39 Motion to Compel in the case of Smith R v. GTFM dated 11/14/05 (NSJ #17) H 40 Marques Haynes HGI stock agreement R (8/1/72) C (NSJ #19) 41 Letter to Fred “Curly” Neal from Garvey H (FUBU & Assoc. re: Cease and Desist only), R (11/20/95)(NSJ #20) 4 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 4 of 56 42 Memo to Fred “Curly” Neal (7/8/83)re: R merchandise payments for White Shadow H NSJ #21) C 43 Letter to Larry “Gator” Rivers from R David Tobin (7/3/90) re: cease and H desist (NSJ #23) Inc 44 GTFM Operating Agreement D-1066 (3/5/98)between FUBU (NSJ #27) 45 Sacks e-mail to Townsend (9/20/05)(NSJ R #28) H (HGI and *Need better copy Jacksons only) 46 Aurum Trademark Registration R (8/10/05)(NSJ #30) 47 Larry “Gator” Rivers Affidavit H (11/21/05)(NSJ #32) 48 Dallas “Big D” Thornton Affidavit R (11/23/05) H (NSJ #33) 49 James “Twiggy” Sanders Affidavit R (11/23/05) H (NSJ #34) 50 Fred “Curly” Neal Affidavit (11/30/05) R (NSJ #35) H 51 Robert “Showboat” Hall Affidavit R (11/21/05) H (NSJ #36) 52 Marques Haynes Affidavit (11/23/05)(NSJ R #37) H 53 Contract between HGI and Lou Dunbar R (9/5/03) (NSJ #38) 5 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 5 of 56 54 Letter to Joyce Szymanski from Rose R Neal (2/2/95)re: cease and desist (NSJ H #39) 55 Fred “Curly” Neal pay stubs (1979-1984) R (NSJ #40) H U 56 Fred “Curly” Neal union settlement with R HGI (1/7/83)(NSJ #41) H 57 Letter to Fred “Curly” Neal from Ira R Drogin (8/29/74) re: NLRB certification H of UBPA Union and CBA (NSJ #43) 58 Curly Neal’s Orlando Magic market R research (6/9/89)Fred Curly Neal press H release (1994), and Neal’s photo of U “Biography” billboard in New York (NSJ #44) 59 Neal Various Endorsement Payments from R HGI (Converse, White Shadow, Coke, ABC, H Midgette, Gilligan’s Island, JVC, C Tonight Show) (NSJ #45) U 60 Memo from Larry Levin (8/16/88) re: R Neal Contract (NSJ #50) H 61 Letter to Fred “Curly” Neal from R Michael Syracuse (5/8/02) re: H (FUBU only) foundation rejection of request for financial support (NSJ #51) 62 HGI Sub-S notes to financial statements R 2004-2005(NSJ #60) H I 63 Letter to Fred “Curly” Neal and Rose R Neal from HGI (10/30/98) re: 1999 HGI H (FUBU only) world tour appearance (NSJ #52) 64 HGI sale to HGI Holdings and Shamrock R transaction (9/27/05)(NSJ #53) H I 65 HGI Foundation Receipt Report (August R 2000-July 2003)(NSJ #58) H I 6 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 6 of 56 66 HGI corporate merger filing as of R 10/6/05 H (NSJ #59) I 67 HGI Foundation Cash Journals (August R 2002-September 2004)(NSJ #62) H 68 Marques Haynes’ Publicity (composite of R Haynes press clippings)(NSJ #65) H C U 69 Marques Haynes and Columbia Pictures R Life Story Right/Consulting Agreement H (8/29/01) U (NSJ #66) 70 Larry “Gator” Rivers HG Publicity Form R (NSJ #67) H C 71 James “Twiggy” Sanders news article R (7/11/04)(NSJ #68) H 72 Greeson/Gillette Correspondence R (2/3/70) re: Lemon Contract H (NSJ #69) C I 73 Haynes Judgment (12/30/64) re: R name/likeness (NSJ #70) 74 Marques Haynes Affidavit (12/8/05) with R exhibits 1)1977 CBA; 2) pension plan; H and 3) Wide World of Sports Supplement I 75 Order and Notice Confirming Plan dated R 5/26/93 in re: International U Broadcasting Corp., IBC Amusement Rides, Inc. and International Theatres Corp. in the US Bankruptcy Court, District of Minnesota, Case Nos. BKY 4- 91-5999; BKY 4-916002; BKY 4-91-6003 (certified)(NSJ #72A) 7 Doc. #516255 v.1 Case 2:04-cv-00299-DGC Document 574-2 Filed 01/18/2007 Page 7 of 56 76 Debtor’s Amended Joint Plan dated R 5/25/93 with attached Order in re: U International Broadcasting Corp., IBC Amusement Rides, Inc. and International Theatres Corp. in the US Bankruptcy Court, District of Minnesota, Case Nos. BKY 4-91-5999; BKY 4-916002; BKY 4-91- 6003 (certified)(NSJ #72B) 77 Debtor’s Amended Joint Disclosure R Statement with exhibits dated 3/3/93 in U re: International Broadcasting Corp, IBC Amusement Rides, Inc.
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