first nfl opt out list report

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERM DISTRICT OF PENNSYLVANIA

IN RE: NATIONAL FOOTBALL LEAGUE PLAYERS’ CONCUSSION INJURY LITIGATION

: : : :

No. 2:12-md-02323-AB

MDL No. 2323

THIS DOCUMENT RELATES TO: ALL ACTIONS

: : : : :

Hon. Anita B. Brody

OPT OUT REPORT SUBMITTED BY THE CLAIMS ADMINISTRATOR

BrownGreer PLC (“BrownGreer”), the Claims Administrator under the proposed

Class Action Settlement Agreement (“Settlement Agreement”) in this matter, submits this

Opt Out Report pursuant to Paragraph 4.j of the July 7, 2014 Preliminary Approval Order

(Document 6084):

1. Report by the Claims Administrator. Paragraph 4.j of the Preliminary

Approval Order directs that BrownGreer file with the Court and serve on Class Counsel and

Counsel for the NFL Parties on or before November 3, 2014, a list of all persons who timely

Opted Out of the Settlement Class. This Report is made pursuant to that Order and provides

complete information on all Opt Out requests received, whether apparently timely or

untimely, and the process used by BrownGreer to receive, review, track, and report on these

materials.

2. Settlement Class Statistics. The Long-Form Notice was mailed to 33,984

potential Settlement Class Members, 25,060 of whom were identified as NFL Football Players

Case 2:12-md-02323-AB Document 6340 Filed 11/03/14 of 11

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(both active and retired) and 8,924 of whom were identified as the relatives of deceased NFL

Football Players.

3. Opt Out Statistics. As explained in this Report and as shown in greater detail in

Exhibits 1 and 2 to this Report, out of the 33,984 known potential Settlement Class Members

described in Paragraph 2 of this Report, BrownGreer received 220 Opt Out requests that appear

to be timely, 14 Opt Out requests that appear to be untimely, and one Revocation of Opt Out

request. These Opt Out requests are summarized in this table for quick reference:

OPT-OUT REQUESTS: SUMMARY

A. TIMELY OPT OUT REQUESTS (See Exhibit 1)

1. Retired NFL Football Players 196

2. Relatives of a Retired NFL Football Player 22

3. Unable to Identify Settlement Class Member Type 2

4. TOTAL 220

B. UNTIMELY OPT-OUT REQUESTS (See Exhibit 2)

5. Retired NFL Football Players 13

6. Relative of a Retired NFL Football Player 1

7. TOTAL 14

C. REVOCATION REQUEST

8. Retired NFL Football Player 1

Exhibits 1 and 2 to this Report identify the Settlement Class Members who submitted these

materials and indicate the results of our review to assess compliance with the terms of the

Settlement Agreement regarding the required content of an Opt Out request, as explained in the

remainder of this Report.


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4. Required Content of Opt Out Requests. Section 14.2(a) of the Settlement

Agreement directed Class Members who wished to exclude themselves from the Settlement

Class to submit their written requests to Opt Out to the Claims Administrator and provides

that any such Opt Out request must contain these seven elements:

(a) The statement “I wish to exclude myself from the Settlement Class in In re National Football League Players’ Concussion Litigation, No. 2:12-md-02323,” or substantially similar clear and unambiguous language;

(b) The printed name of the Settlement Class Member;

(c) The address of the Settlement Class Member;

(d) The telephone number of the Settlement Class Member;

(e) The date of birth of the Settlement Class Member;

(f) A copy of the driver’s license or other government-issued identification of the Settlement Class Member; and

(g) The dated personal signature of the Settlement Class Member.

5. Opt Out Deadline. Paragraph 4.g of the Preliminary Approval Order required

that Opt Out requests must be postmarked on or before October 14, 2014.

6. Post Office Box for Receipt of Potential Opt Outs. On July 2, 2014, BrownGreer

set up a P.O. Box (P.O. Box 25369, Richmond, VA 23260) to which Settlement Class Members

could send their Opt Out requests. The Long-Form Notice and the official public website for the

Settlement Agreement, https://www.NFLConcussionSettlement.com, instructed Settlement

Class Members to direct their Opt Out requests to this P.O. Box. BrownGreer retrieved mail

from this P.O. Box each business day. During the weeks of and following the Opt Out deadline

(October 13–25, 2014), BrownGreer retrieved mail from this P.O. Box twice each business day

and each Saturday.


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7. Mail Intake. To create a permanent digital record of each Opt Out request,

BrownGreer intake specialists scanned each piece of mail received in the P.O. Box to create a

PDF image of the envelope and its contents and saved the resulting PDF to a secure network

drive dedicated to this Program. BrownGreer also has retained the hard copies of all these

documents in a secure storage area in one of BrownGreer’s offices in Richmond, Virginia.

8. Claims Administrator Email Inbox. On August 7, 2014, BrownGreer set up an

email address, [email protected], where Settlement Class

Members and others could direct general questions about the Settlement Agreement and

proposed Settlement Program (the “CA Inbox”). This email address appears on the public

website for the Settlement Agreement. Though the Long Form Notice and the website instructed

Settlement Class Members to mail their Opt Out requests to the Claims Administrator’s P.O.

Box, one Settlement Class Member emailed an Opt Out request to this CA Inbox.

9. The Notice ID for Each Class Member. Between October 2013 and July 2014,

BrownGreer created a Master Mailing List that included all known Retired NFL Football Players

and the relatives of deceased NFL Football Players who could be identified, to be used in

mailing Notice of the proposed Settlement Agreement to these known Settlement Class

Members. This Master Mailing List contained a total of 33,984 individuals, each of whom was

assigned a unique identifying number referred to as the “Notice ID.” Upon receiving an Opt Out

request, BrownGreer first searched the Master Mailing List for the Settlement Class Member to

determine his or her Notice ID, to ensure that we correctly identify and track each person and to

avoid double-counting any person.

10. NFL Employment Information. After determining the Notice ID of a person

who had sent us an Opt Out request, BrownGreer searched its database and the NFL statistics at


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NFL.com to attempt to determine whether the Settlement Class Member was a Retired NFL

Football Player, a relative of a Retired NFL Football Player, or someone acting in some capacity.

If we could identify the person as a Retired NFL Football Player, BrownGreer recorded the

names of any NFL teams for which he played and the years he played, based upon the available

information. If we could identify the Settlement Class Member as a relative of a Retired NFL

Football Player and we could determine the name of the player, BrownGreer recorded that

player’s football employment information.

11. NFL Settlement Program Portal. To facilitate the organization, management and

access to documents and other information of the Claims Administrator relating to the Settlement

Agreement, BrownGreer designed, coded, tested, implemented and hosts a secure website called

the NFL Settlement Program Portal (“NFL Portal”). This internet interface allows authorized

representatives of Class Counsel and Counsel for the NFL Parties to access, view, and download

documents and information. Only persons authorized by BrownGreer can access the NFL Portal,

and BrownGreer assigns each user a specific role that limits what documents the user may

access.

12. Review of Opt Out Requests. BrownGreer also designed, coded, tested,

implemented and hosts a customized software application to track each Opt Out request and to

store information produced in the review of these requests. A team of specially trained

BrownGreer reviewers examined every Opt Out request to link the document to the correct

Settlement Class Member and to identify and record the Class Member’s counsel and law firm, if

represented. If the Settlement Class Member was not on the Notice Mailing List, we added the

name to our NFL Settlement database and created a new Notice ID for him or her. We then

reviewed each Opt Out request to record the attributes of the request and whether it contained the


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seven elements of an Opt Out mandated by Section 14.2(a) of the Settlement Agreement and

listed in Paragraph 4 of this Report.

13. Potential Opt Outs Tracking Report. BrownGreer created and maintained a

comprehensive report tracking all Opt Out requests received, entitled the “NFL 1001-Potential

Opt Outs” report. In this NFL 1001-Potential Opt Outs report, BrownGreer recorded the

following data points for each Opt Out request:

(1) Last Name: The last name of the Settlement Class Member;

(2) First Name: The first name of the Settlement Class Member;

(3) Middle Name or Initial: The middle name or initial of the Settlement Class Member;

(4) Address: The street address of the Settlement Class Member;

(5) City: The city of the Settlement Class Member’s mailing address;

(6) State: The state of the Settlement Class Member mailing address;

(7) Postal Code: The Zip Code or other postal code of the Settlement Class Member’s mailing address;

(8) Phone Number: The phone number of the Settlement Class Member;

(9) Date of Birth: The date of birth of the Settlement Class Member;

(10) Government-Issued ID: Whether the Settlement Class Member included a copy of a government-issued ID;

(11) Signature Type: Whether the Settlement Class Member signed his or her Opt Out request by hand, typed his or her signature, or did not provide a signature;

(12) Signature Date: The date on which the Settlement Class Member signed the Opt Out request;

(13) Date of Receipt: The date on which BrownGreer received the Opt Out request;


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(14) Postmark Date: The postmark date on the envelope containing the Opt Out request, or whether that the date was not present or was illegible;

(15) Sent By: The method by which the Settlement Class Member submitted the Opt Out request (e.g., by regular mail, certified mail, FedEx, or UPS);

(16) Revocation Request: Whether the Settlement Class Member has submitted an Opt Out revocation pursuant to Section 14.2 of the Settlement Agreement, which allows such revocations until the Final Approval Date;

(17) Law Firm Name: The name of the law firm representing the Settlement Class Member, if provided;

(18) On the Mailing List: Whether the Settlement Class Member appeared on the Master Mailing List;

(19) Notice ID: The Notice ID of the Settlement Class Member, if he or she appeared on the Master Mailing List;

(20) NFL Player: The Name of the Retired NFL Football Player related to the Settlement Class Member, if the person could be identified as a relative of a player;

(21) Relationship to Player: The relationship of the Settlement Class Member to an Retired NFL Football Player, if known;

(22) Player Deceased or Living: Whether the Retired NFL Football Player related to the Settlement Class Member is deceased or living;

(23) Potential Opt Out Received from Player/Estate: Whether the Opt Out request was from a Retired NFL Football Player or from the estate of a deceased NFL Player;

(24) Team(s): The names of the team, or teams, that employed the Retired NFL Football Player during his NFL career, as best we could determine from available data; and

(25) Seasons: The years the Retired NFL Football Player played for the NFL, as best we could determine from available data.

14. Timeliness of the Opt Out Requests. BrownGreer also tracked whether an Opt

Out request appeared to be timely or untimely under the directive in Paragraph 4.g of the


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Preliminary Approval Order that such requests be postmarked on or before October 14, 2014.

BrownGreer applied the following rules to measure whether an Opt Out request was timely:

(a) If the postmark date is present and legible, that date controls timeliness.

(b) If there is no postmark date or an apparent date is illegible, the date of BrownGreer’s receipt of the request at the P.O. Box is used to determine timeliness.

(c) If the Settlement Class Member sent the Opt Out request by email to the CA

Inbox, the date the Class Member sent the email is used to determine timeliness.

(d) If the Class Member sent the Opt Out request by a carrier service the date the Class Member placed the document in the hands of the carrier is used to determine timeliness, for that date serves as the functional equivalent of the postmark date that would appear on a mailed document.

15. Reporting Opt Out Requests to Class Counsel and Counsel for the NFL Parties.

Section 14.2(a) of the Settlement Agreement requires the Claims Administrator to provide copies

of all Opt Out requests to Class Counsel and Counsel for the NFL Parties within seven days of

receipt. BrownGreer actually sent copies of Opt Out requests to Class Counsel and Counsel for

the NFL Parties each business day and within one business day of receipt, along with the NFL

1001-Potential Opt Outs report, rather than using the entire seven days allowed for this purpose.

During the period immediately surrounding the Opt Out deadline (October 13–25, 2014),

BrownGreer sent copies of Opt Out requests and the NFL 1001-Potential Opt Outs report to

Class Counsel and Counsel for the NFL Parties twice daily.

16. Revocation of Opt Out Requests. Section 14.2(c) of the Settlement Agreement

directed that any Class Member who wished to revoke his or her Opt Out request to submit a

Revocation of Opt Out request to Class Counsel and Counsel for the NFL Parties. One Class

Member submitted such a Revocation of Opt Out request. Class Counsel and Counsel for the

NFL Parties forwarded that Revocation of Opt Out request to BrownGreer.


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17. Reports Attached as Exhibit 1 and Exhibit 2. Exhibit 1 to this Report identifies

the Opt Out requests that appear to be timely. Exhibit 2 to this Report identifies the Opt Out

requests that appear to be untimely. We have divided the lists into sections by Class Member

Type (Retired NFL Football Players, Relatives of Retired NFL Football Players, and Unable to

Identify Settlement Class Member Type). In these Exhibits:

(a) Column 1 provides the Settlement Class Member’s full name. We have listed these persons within each section in alphabetical order by last name.

(b) Column 2 indicates the Settlement Class Member Type, based on our research. In the Relatives of a Retired NFL Player sections of the Exhibits, we have also included the name of the Retired NFL Football Player to whom the Settlement Class Member appears to be related.

(c) Columns 3-8 reflect the results of our review of the materials to assess the presence of

the elements required by Section 14.2(a) of the Settlement Agreement and listed in Paragraph 4 of this Report.

(d) Column 9 shows the date we used to measure the timeliness of an Opt Out request. Where Column 9 shows only a date, it means that we received the material by mail with a postmark. In those instances, the date shown is the postmark date. If we received the Opt Out request by some other means or if the postmark was not present, Column 9 describes the method of receipt and then shows the date that controls the timeliness of the Opt Out under the rules of decision set out in Paragraph 14 of this Report.


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Respectfully submitted,

CLAIMS ADMINISTRATOR

By: /s/ Orran L. Brown

Orran L. Brown VSB No. 25832 BROWNGREER PLC 250 Rocketts Way Richmond, VA 23231 Telephone: (804) 521-7201 Facsimile: (804) 521-7299 Email: [email protected]

Date: November 3, 2014


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CERTIFICATE OF SERVICE

The undersigned hereby certifies that the foregoing NFL Concussion Settlement: Opt

Out Report was filed electronically this 3rd day of November, 2014, and was served

electronically upon Class Counsel, counsel for the NFL Parties and all counsel of record by the

United States District Court for the Eastern District of Pennsylvania’s electronic filing system.

/s/ Orran L. Brown Orran L. Brown Virginia State Bar No. 25832 BrownGreer PLC 250 Rocketts Way Richmond, Virginia 23231 Telephone: (804) 521-7201 Facsimile: (804) 521-7299 Email: [email protected]


EXHIBIT 1

Case 2:12-md-02323-AB Document 6340-1 Filed 11/03/14 Page 1 of 8

EXHIBIT 11. Settlement Class Member

Name2. Settlement Class

Member Type3. Address Provided?

4. Phone Number

5. DOB Provided?

6. Government ID Provided?

7. Personal Signature

8. Signature Date

9. Postmark Date

1. Abdullah, Hamza Retired NFL Football Player Yes Yes Yes Yes Yes Yes 9/15/142. Acks, Ronald William Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/143. Ahanotu, Chidi Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/144. Alexander, Jr., Charles F. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/145. Arnett ,Jon Dwane Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14

6. Ashley Jr., Walker Lee Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

7. August, Steve Paul Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/148. Bain, William Ernest Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/149. Ballard, Howard Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1410. Banaszak, Andrew Peter Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/1411. Barnes, Billy Ray Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14

12. Barnett, Timothy Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

13. Bass, Michael Thomas Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1414. Baugh, Thomas Anthony Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1415. Baumgartner, Steven Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1416. Beban, Gary J. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 8/15/1417. Bell, Bobby L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1418. Bell, Gregory Leon Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/1419. Bernard, Walter Retired NFL Football Player Yes No Yes Yes Yes No 10/14/1420. Berton, Sean Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/1421. Bethea, Elvin L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1422. Bielski, Richard Adam Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1423. Bing, Darnell L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/6/1424. Bingham, Gregory Raleigh Retired NFL Football Player Yes No Yes Yes Yes Yes 10/13/1425. Blackshear, Rodney T. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1426. Blair, Michael Retired NFL Football Player Yes No Yes Yes Yes No 10/14/1427. Bonness, Richard K. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1428. Brannon, Robert Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1429. Brightful, Lamont Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/13/1430. Brooks IV, Robert L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1431. Brown, Corwin Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/20/14

32. Brown, Mike Retired NFL Football Player No No No No No NoEmail

10/13/1433. Brown, Ronald Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

A. Retired NFL Football Players

TIMELY OPT OUT REQUESTS





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


34. Bryant, Trent B. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

35. Burkett, Walter J.1 Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14

36. Bush, Lewis F.Retired NFL Player ‐Filed by

RepresentativeYes No No Yes Yes Yes 10/14/14

37. Campbell, Woodrow Lamar Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1438. Carter, Tyrone Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

39. Cartwright, Roderick R. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

40. Carver, Shante Retired NFL Football Player Yes No Yes Yes Yes Yes 10/8/1441. Clapp, II, Thomas P. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1442. Cline, Jr., Anthony Francis Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1443. Cobb, Marvin Lawrence Retired NFL Football Player Yes Yes Yes No Yes Yes 10/7/1444. Commiskey, Charles E. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14

45. Cooper, Alexander Louis Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

46. Cordileone, Louis Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1447. Cosbie, Douglas Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1448. Cribbs, Joshua Jamall Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1449. Cromartie, Keaton Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1450. Crumpler, Algernon D. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1451. Crumpler, Carlester T. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1452. Darling, Devard Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/1453. David, Jason Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/1454. Davis, Terrell Lamar Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

55. DeCarlo, Sr., Arthur A.Retired NFL Player ‐Filed by

RepresentativeYes Yes Yes Yes Yes Yes 10/14/14

56. DeLamielleure, Joseph Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1457. Dennis, III, Albert R. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1458. Dorris, Andrew Michael Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1459. Dorsett, Tony Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1460. Douglas, Cody Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1461. Douglass, Bobby Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1462. Earl, Glenn Eugene Retired NFL Football Player Yes Yes Yes No Yes Yes 10/14/1463. Eber, Richard Lee Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1464. Edelman, Bradley Mart Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1465. Fahnhorst, Keith V. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1466. Fanning, Michael Lavern Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/1467. Fantetti, Ken Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/1468. Flatley, Paul R. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1469. Forsberg, Fred C Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/1470. Gabriel, Roman Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/1471. Grant, Robert B. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/9/1472. Gray, Quinn F. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

73. Green, Roy Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


74. Grier, Roosevelt Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/6/14

75. Griffin, Jr., Leonard James Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

76. Griffin, Raymond E. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 8/19/14

77. Hackett, Barry Dean Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

78. Hamilton, Ben Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

79. Hamilton, Harry E. Retired NFL Football Player Yes Yes No No Yes Yes 10/14/1480. Harrison, Jerome Charles Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

81. Harry, Emile Michael Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

82. Healy Jr., William R. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1483. Hicks, Dwight Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/1484. Hill, Calvin Retired NFL Football Player Yes Yes Yes No Yes Yes 10/14/1485. Hill, Kent Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1486. Hill, Marcus A. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1487. Hilliard, Lex Douglas Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1488. Hoover, Bradley Ray Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1489. Iorio, Joseph W. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/9/1490. Izzo, Larry Retired NFL Football Player Yes No Yes Yes No Yes 10/14/1491. Jarvis, John Bruce Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/1492. Jefferson, Jr., Roy Lee Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1493. Jenke, Noel C. Retired NFL Football Player Yes Yes Yes Yes Yes No 10/14/1494. Johnson Jr., Ted C. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/1495. Jones, Donald Ray Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

96. Jones, Frederick Cornelius Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

97. Kelly, Eric Francheste Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

98. Kelly, II, Patrick Retired NFL Player ‐Filed by

RepresentativeYes Yes No Yes Yes Yes 10/14/14

99. Kennedy, Jr., Jimmy Wayne Retired NFL Football Player Yes No Yes Yes Yes Yes 10/10/14100. Kenney, Stephen F. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14101. Kenney, William Patrick Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14102. Kingsriter, Douglas James Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/13/14103. Koncar, Mark Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/14104. Kosar, Bernard J. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14105. Krakau, Mervin F. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14106. Krause, Paul James Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14107. Kunz, George J. Retired NFL Football Player Yes Yes Yes Yes No No 10/14/14108. Lanier, Sr., Willie Edward Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14109. LaRose, Marvin Daniel Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14110. Larson, Gregory K. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/14

111. Lewis, Albert R. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

112. Lowe, Woodrow Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/14





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


113. Lurtsema, Robert Ross Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14114. Lynch, Benjamin John Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/9/14115. Maas, William Thomas Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/2/14

116. Martin, Christopher Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

117. Martin, Robbie L Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/14118. Massaquoi, Mohamed Jah Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/9/14119. Maxwell Jr., Vernon Leroy Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14120. May, Jr., Bert Deems Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

121.McAlister, Christopher James

Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

122. McAllister, Dulymus J. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14123. McDougle Jr., Jerome Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

124. McNair, Todd D. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

125. Meisner, Lee Edward Retired NFL Football Player Yes No Yes Yes Yes Yes 7/31/14126. Merritt Sr., David L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/6/14

127. Mincy, Charles Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

128. Minter, Cedric Retired NFL Football Player Yes No Yes No Yes Yes 7/30/14129. Miree, Brandon C. Retired NFL Football Player Yes Yes Yes Yes Yes No 10/14/14

130. Morey, Sean J. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

131. Morton, Larry Craig Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/14132. Nelson, Curtis Shane Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14133. Nelson, Jimmie Dirk Retired NFL Football Player Yes Yes Yes Yes Yes Yes 7/29/14134. Niswanger, Rudolph N. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14135. Oliver, Darryl H. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14136. Oliver, Paul J. Retired NFL Football Player Yes Yes No Yes Yes Yes 10/8/14137. Olkewicz, Neal Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/14138. Owens, Brigman Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/14139. Owens, Mel T. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

140. Palmer, Paul W. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

141. Parker, J'vonne Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14142. Parrish, Bernard P. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14143. Pastorini, Dan Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14144. Patrick, Allen Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

145. Pearson, Jayice Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

146. Peters, Scott Retired NFL Football Player Yes Yes Yes No Yes Yes 10/9/14

147. Phillips, Joseph Gordon Retired NFL Football Player Yes Yes Yes Yes Yes Yes7/22/14; 7/23/14; 10/14/14

148. Porter, Kevin Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


149. Preece, Steven Packer Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14150. Pritchard, Ronald David Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/9/14151. Ragon, Randy D. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14152. Reed, Andre D. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14153. Riggins, Robert John Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14154. Robinson, Johnny Nolan Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14155. Rogers, George W. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

156. Royal, Jr., Robert S. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

157. Rudnay, John Carl Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/14

158.Schaefering, Brian Christopher

Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

159. Scott III, Jacob E Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/6/14

160. Scott, Edward Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

161. Seals, George E. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

162. Seau, Jr., Tiaina B.Retired NFL Player ‐Filed by


163. Senser, Joseph M. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14164. Sharpe, Luis Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14165. Sherk, Jerry Martin Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14166. Simonini, Ed Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14167. Sims, Jr., George Pollard Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/14

168. Smith, Chris M. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

169. Smith, Jesse Daley Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/8/14

170. Smith, John Thomas Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

171. Smith, Neil O. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

172. Stant, Patrick M. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14173. Steagall, Derrick Retired NFL Football Player Yes Yes Yes Yes Yes No 10/14/14174. Steed, Joel E. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14175. Stein, Robert Allen Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

176. Still, Arthur B. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

177. Tant, Jay W. Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

178. Terry, Douglas Maurice Retired NFL Football Player Yes Yes Yes Yes Yes YesDelivery10/14/14

179. Thomas, Charles G. Retired NFL Football Player Yes No Yes Yes Yes Yes 10/14/14180. Toefield, LaBrandon Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14181. Truax, III, William F. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14182. Trufant, Marcus Lavon Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14183. Vanover, Tamarick Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14184. Voigt, Stuart A. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


185. Walker, George Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/10/14186. Walls, Charles Wesley Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14187. Walter, Tyson Barrett Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14188. Washington, Mark H. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/11/14189. Westbrook, Michael Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14190. White, Edward Alvin Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14

191. Wilbur, John Retired NFL Player ‐Filed by


192. Williams, Ralph Retired NFL Football Player Yes Yes Yes Yes Yes Yes10/14/14; 10/20/14

193. Williams, Roosevelt Retired NFL Football Player Yes No No No Yes Yes 10/9/14194. Wright, Jeffrey Ralph Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/7/14195. Yary, Anthony Ronald Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/14/14196. Youngblood, George Alton Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/13/14

1. Settlement Class Member Name

2. Settlement Class Member Type

3. Address Provided?

4. Phone Number Provided?

5. DOB Provided?


7. Personal Signature Provided?

8. Signature Date

Provided?

9. Postmark Date

197. Baugh, Jean M.Derivative/Family ‐ Thomas

BaughYes Yes Yes Yes Yes Yes 10/14/14

198. Bush, Danielle Derivative/Family ‐ Lewis

BushYes No Yes Yes Yes Yes 10/14/14

199. Bush, Deedee Derivative/Family ‐ Lewis


200. Bush, Jr., Lewis F.Derivative/Family ‐ Lewis


201. Bush, Makai Derivative/Family ‐ Lewis


202. Davis, Roberta LeeDerivative/Family ‐ Douglas

S. DavisYes Yes Yes Yes Yes Yes 8/1/14

203. Kelly, III, Patrick Derivative/Family ‐ Patrick

KellyYes Yes Yes Yes Yes Yes 10/14/14

204. Kelly, Kari Derivative/Family ‐ Patrick

KellyYes Yes Yes Yes Yes Yes 10/14/14

205. Kenney, Sandra LouiseDerivative/Family ‐ William

P. KenneyYes Yes Yes Yes Yes Yes 10/14/14

206. Lamana, Virginia PDerivative/Family ‐ Peter

LamanaYes Yes Yes Yes Yes Yes 8/5/14

207. Lesane, Elizabeth TurnerDerivative/Family ‐ James

LesaneYes Yes Yes Yes Yes Yes 9/11/14

208. Oliver, Chelsea C.Derivative/Family ‐ Paul

OliverYes Yes Yes Yes Yes Yes 10/8/14

209. Oliver, Silas J.Derivative/Family ‐ Paul


Subtotal of Retired NFL Football Players

B. Relatives of a Retired NFL Football Player

196





4. Phone Number

5. DOB Provided?



8. Signature Date

9. Postmark Date


210. Oliver, Simeon J.Derivative/Family ‐ Paul


211. Seau, Hunter Derivative/Family ‐ Tiaina B.

Seau, Jr.Yes Yes Yes Yes Yes Yes 10/11/14

212. Seau, Jake R.Derivative/Family ‐ Tiaina B.


213. Seau, Luisa Derivative/Family ‐ Tiaina B.


214. Seau, Sydney B.Derivative/Family ‐ Tiaina B.


215. Seau, Tiaina Derivative/Family ‐ Tiaina B.


216. Seau, Tyler C.Derivative/Family ‐ Tiaina B.


217. Smith, Dione ElizabethDerivative/Family ‐ John

WilburYes Yes Yes Yes Yes Yes

10/14/14; 10/21/14

218. Tant, Natalie Derivative/Family ‐ Jay Tant Yes Yes Yes Yes Yes YesDelivery10/14/14





5. DOB Provided?



8. Signature Date

Provided?

9. Postmark Date

219. Phillips, Elizabeth D. Unable to Identify Yes Yes Yes Yes Yes Yes 10/13/14220. Simpson, William C. Unable to Identify Yes Yes Yes Yes Yes Yes 10/14/14

1This Opt Out request is subject to the one Revocation of Opt Out request BrownGreer received.

220

2

C. Unable to Identify Settlement Class Member Type

22

Total Timely Opt Out Requests

Subtotal of Unable to Identify Settlement Class Member Type

Subtotal of Relatives of a Retired NFL Football Player


EXHIBIT 2


EXHIBIT 2





5. DOB Provided?



8. Signature Date

Provided?

9. Postmark Date

1. Anderson, Ottis J. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/142. Babineaux, Jordan Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/143. Bebout, Nick Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/144. Buggs, Daniel Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/14

5. Buggs, Wamon C. Retired NFL Football Player Yes Yes Yes Yes Yes YesMissing10/17/14

6. Cole Sr., Robin Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/14

7. Ford, Bernard Retired NFL Football Player Yes Yes Yes Yes Yes YesMissing10/18/14

8. Gayle, Shaun Retired NFL Football Player Yes Yes Yes Yes Yes YesMissing10/21/14

9. Harris, Charles W. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/31/1410. Horn, Joseph Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/1411. Rentzel, Thomas L. Retired NFL Football Player Yes Yes Yes Yes Yes Yes 10/15/14

12. Richards, Rex Retired NFL Football Player Yes Yes Yes No Yes YesMissing10/22/14

13. Stoepel, Terry Retired NFL Football Player Yes Yes Yes Yes Yes NoMissing10/22/14





5. DOB Provided?



8. Signature Date

Provided?

9. Postmark Date

14. Rogers, Loretta Derivative/Family ‐ George

RogersNo No No No No No

Email10/20/141

A. Retired NFL Football Players

UNTIMELY OPT OUT REQUESTS

1Loretta Rogers filed her Opt Out request with the Court and Class Counsel emailed it to BrownGreer on 10/20/14. The Certificate of Service attached to the Opt Out request recites that it was mailed to the Court on 10/14/14 but we show the date of our email receipt, which is all we can verify. There is no postmark.

Subtotal of Relative of a Retired NFL Football Player

Total Untimely Opt Out Requests

Subtotal of Retired NFL Football Players 13

1

14

B. Relative of a Retired NFL Football Player


first nfl opt out list report

Documents