Case: 1:11-cv-06356 Document #: 35-1 Filed: 01/13/12 Page 1 of 15 PageID #:573

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ADRIAN ARRINGTON, DEREK OWENS, MARK TURNER, and ANGELA PALACIOS, individually and on behalf of all others similarly situated, Case No. 11-cv-06356 Plaintiffs, v. NATIONAL COLLEGIATE ATHLETIC ASSOCIATION, Defendant. Hon. Sharon Johnson Coleman JURY DEMAND

JOINT STATUS REPORT Pursuant to Fed. R. Civ. P. 26 and this Courts Standing Order, Plaintiffs, individually and on behalf of all others similarly situated, and Defendant, through their respective attorneys, submit the following: I. NATURE OF THE CASE1 A. Nature of the Claims Asserted in the Complaint and Any Counterclaims.

On November 21, 2011, Plaintiffs filed their [Corrected] Consolidated Class Action Complaint in which they allege that the NCAA has failed to meet its responsibility to safeguard student athletes through a pattern of negligence and inaction with respect to concussions and concussion-related maladies sustained by its student-athletes, all the while profiting immensely from those same student-athletes.

The attorneys of record, including the lead trial attorneys, are identified in the signature blocks to this report.

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Plaintiffs allege, specifically, that the NCAA has failed to, inter alia: (1) address and/or correct the coaching of tackling, checking or playing methodologies that cause head injuries; (2) educate coaches, trainers and student athletes as to the symptoms indicating possible concussions; (3) implement system-wide return to play guidelines for student-athletes who have sustained concussions; (4) implement system-wide guidelines for the screening and detection of head injuries; (5) implement legislation addressing the treatment and eligibility of student-athletes who have sustained multiple concussions in the course of play; and (6) implement a support system for student-athletes who, after sustaining concussions, are left unable to either play their sport or even lead a normal life. Individually, and on behalf of all others similarly situated, Plaintiffs assert claims for negligence, fraudulent concealment, unjust enrichment and medical monitoring. Plaintiffs seek compensatory and declaratory relief that would require the NCAA to adopt certain corrective measures, as well as financial recovery for Plaintiffs and class members long-term and chronic injuries, including their financial losses and expenses, and the establishment of a medical monitoring program that includes, among other things: (1) establishing a trust fund, in an amount to be determined, to pay for the medical monitoring of all past, current and future NCAA student-athletes, as frequently and appropriately as necessary, (2) notifying all medical monitoring class members in writing that they may require frequent medical monitoring, and (3) providing information to treating team physicians to aid them in detecting concussions or subconcussions and to assist them in determining when the player is subjected to an increased risk of harm. Plaintiffs further seek award of prejudgment interest, costs and attorneys fees. And, because this case is a putative nationwide class action, Plaintiffs also seek certification of the proposed Classes under to Fed. R. Civ. P. 23.

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On December 21, 2011, Defendant filed its Answer and Affirmative Defenses. Defendant has not asserted any counterclaims but has interposed a number of affirmative defenses and respectfully submits that Plaintiffs cannot meet the requirements of Fed. R. Civ. P. 23 for either of their two proposed classes. B. Plaintiffs Identify The Following Legal And Factual Issues.

The major factual issues in the case include, inter alia, whether the NCAA has failed to: (1) address and/or correct the coaching of playing methodologies that cause head injuries, (2) educate coaches, trainers and student-athletes as to the symptoms indicating possible concussions, (3) implement system-wide return to play guidelines for student-athletes who have sustained concussions, (4) implement system-wide guidelines for the screening and detection of head injuries, (5) implement legislation addressing the treatment and eligibility of student-athletes who have sustained multiple concussions in the course of play, and (6) implement a support system for student-athletes who, after sustaining concussions, are left unable to either play their sport or even lead a normal life. The major legal issues in the case include, inter alia: (1) whether the NCAA and its members are negligent and/or have been unjustly enriched; (2) whether Plaintiffs and the Classes are entitled to compensatory or other forms of damages, and other monetary relief and, if so, in what amount(s); (3) whether Plaintiffs and the Classes are entitled to equitable relief, including, but not limited to, medical monitoring and other injunctive relief; and (4) whether class certification of the Plaintiff Classes and/or Defendant Classes under Fed. R. Civ. P. 23(a), (b)(2) and (b)(3) is appropriate. C. Defendant Identifies The Following Factual And Legal Issues.

The major factual issues in this case include: (1) what the cause(s) of Plaintiffs alleged injuries are and whether those causes are attributable in whole or in part to persons and entities 3
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that are not parties to this case; (2) what role Plaintiffs played vis--vis their alleged injuries; (3) whether the concussion-related information the NCAA allegedly concealed was publicly available; (4) whether Plaintiffs reasonably expected to be compensated for playing college sports; (5) whether Plaintiffs were aware of the risks associated with the sports they played, including the risk of sustaining concussions; (6) the nature and extent of Plaintiffs alleged injuries; and (7) whether Plaintiffs reasonably relied on the NCAAs alleged failure to disclose information regarding concussions. The major legal issues in this case include: (1) whether Plaintiffs and their counsel can satisfy the requirements of Fed. R. Civ. P. 23 for either of their proposed classes; (2) whether the parties that would be necessary and indispensible for adjudication of Plaintiffs claims are before the Court and are otherwise subject to the personal and subject-matter jurisdiction of this Court; (3) whether the law applicable to the claims of Plaintiffs and the proposed classes varies; (4) whether the NCAA owed Plaintiffs a duty and, if so, the scope of that duty; (5) whether Plaintiffs assumed the risks of injury associated with the sports they played, including the risk of sustaining concussions; (6) whether Plaintiffs claims are time-barred under the applicable statutes of limitations; and (7) whether certification of the proposed classes would result in a denial of due process to the NCAA and to members of the proposed classes. II. PENDING MOTIONS On January 11, 2011, Plaintiffs filed a Motion to Strike Affirmative Defenses, which was noticed for Friday, January 20, 2011 at 9:00 a.m. No deadlines have been set. III. DISCOVERY A. Limits in Rules 30 and 33

Given the stage of the case, neither party has propounded document requests or interrogatories. The Parties agree that the presumptive limits on interrogatories in Fed. R. Civ. P. 4
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33(a)(1) shall not apply. The NCAA shall be limited to 25 interrogatories for each named Plaintiff. Plaintiffs shall be limited to 25 interrogatories. Given the long history of negligence by the NCAA alleged by Plaintiffs, as well as the number of member schools under NCAAs control, Plaintiffs request an extension of Rule 30s deposition limit to 25 depositions. Based on the fact that there are four Plaintiffs at four different schools alone, and it is likely there are at least three people at each school with knowledge and information relevant to each Plaintiff (not including the persons at the NCAA with knowledge related to the Class as a whole), it would be prejudicial to Plaintiffs to limit the depositions of fact witnesses to ten. The NCAA proposes that the presumptive limits on depositions in Fed. R. Civ. P. 30(a)(1) shall apply and each party shall be limited to 10 depositions, including depositions of fact witnesses, depositions pursuant to Fed. R. Civ. P. 30(b)(6), and depositions of non-party witnesses. This limit does not include expert depositions. As set forth below, the NCAA proposes giving priority to discovery related to class certification and to such merits issues as inform the class decision. While it is conceivable that individuals who work at named Plaintiffs respective schools may have information relevant to the merits of Plaintiffs claims, the NCAA believes that 10 depositions for each party will provide ample opportunity for discovery relevant to class certification. B. Scope of Discovery 1. Plaintiffs Position.

Plaintiffs anticipate that they will propound discovery regarding such areas as: (1) the NCAAs policies and procedures, if any, regarding the protection of student-athletes from head injuries; (2) the scope of NCAAs knowledge regarding head injuries suffered by studentathletes; (3) instructions considered and/or implemented for member institutions regarding head 5
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injuries suffered by student-athletes; (4) the NCAAs efforts, if any, to warn student-athletes regarding head injuries; (5) the revenues collected by the NCAA; and (6) the information needed to aid treating team physicians in detecting head injuries. Plaintiffs have proposed a 9-month discovery period for all fact discovery, and disagree with Defendants position that this period should apply only to class discovery. Defendants factually-untethered attempt to bifurcate class from merits is inappropriate where the Supreme Court, the Seventh Circuit and courts in this District have repeatedly recognized that the issues presented by a motion for class certification are intrinsically intertwined with the merits of the plaintiffs case. See, e.g., Coopers & Lybrand v. Livesay, 427 U.S. 463, 469 (1978) (commenting that the class determination generally involves considerations that are enmeshed in the factual and legal issues comprising the plaintiffs cause of action)(internal quotation omitted); Blair v. Equifax Check Servs., 181 F.3d 832, 835 (7th Cir. 1999) (Disputes about class certification cannot be divorced from the merits.); Superior Beverage Co. v. Owens-Illinois, Inc., 1986 U.S. Dist. LEXIS 17729 (N.D. Ill. 1986) (observing that the border between full merits and class certification discovery is at best amorphous). Though Defendant suggests that bifurcation is routinely order[ed], the well-accepted treatise on class actions, Newberg, suggests bifurcation is the exception, not the rule, noting that [d]iscovery on the merits should not normally be stayed pending so-called class discovery, because class discovery is frequently not distinguishable from merits discovery, and classwide discovery is often necessary as circumstantial evidence even when the class is denied. 3 Alba Conte & Herbert Newberg, NEWBERG ON CLASS ACTIONS 7.8 at 25 (4th ed. 2002) (emphasis added). Not surprisingly, Courts have recognized that where discovery relating to class issues overlaps substantially with merits discovery, bifurcation will result in duplication of efforts and

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needless line-drawing disputes. Hines v. Overstock.com, Inc., 2010 U.S. Dist. LEXIS 70205 (E.D.N.Y. July 13, 2010).2 Given this backdrop, Plaintiffs would be prejudiced under Defendants proposal, forced to litigate under a proposal that permits Defendant to decide initially whether Plaintiffs have asked for class discovery or merits discovery, then requires Plaintiffs to litigate any dispute: Simply stated, if district courts as neutral arbiters of the law find the distinction between merits and class issues to be murky at best, and impossible to discern at worst, the Court cannot imagine how parties with an incentive to hold back damaging evidence, can properly draw the line between these categories of evidence during phased discovery. Lakeland Reg'l Med. Ctr., Inc. v. Astellas US, LLC, 2011 U.S. Dist. LEXIS 16684, at *5-6 (M.D. Fla. Feb. 7, 2011) (denying bifurcation). While the Federal Rules could easily have provided for a stay of discovery pending class certification[,] they did not, and where [d]iscovery relating to class certification is closely enmeshed with merits discovery, and in fact cannot be meaningfully developed without inquiry into basic issues of the litigation, bifurcation is questionable at best. Gray v. First Winthrop Corp., 133 F.R.D. 39, 41 (N.D. Cal. 1990). Here, Defendant fails to identify any fact particular to this case that justifies bifurcation. And, in the Rule 26(f) conference, Plaintiffs explicitly noted that they would consider and confer in good faith on each individual discovery request if Defendant identified certain areas to be

See also In re SemGroup Energy Partners, L.P., 2010 U.S. Dist. LEXIS 135209 (N.D. Okla. Dec. 21, 2010) ([T]he court believes discovery related to class certification is so closely intertwined with merits discovery that bifurcation would be unworkable. An order restricting discovery to class issues would be impracticable because of the closely linked issues, and inefficient because it would be certain to require ongoing supervision of discovery.); In re Plastics Additives Antitrust Litig., 2004 U.S. Dist. LEXIS 23989 (E.D. Pa. Nov. 29, 2004) (Bifurcation would also belie principles of judicial economy, as the Court may be forced to spend time and resources resolving discovery disputes over what is merit discovery as compared to class discovery.).

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prioritized over others, but explained that it did not make sense to make sweeping divisions without talking about specific requests.3 Finally, Defendant argues that Plaintiffs will not succeed under Rule 23 and therefore discovery should be phased. However, Defendants' attempt to pre-argue the class certification issue is unpersuasive, particularly where "[d]iscovery relating to class certification is closely enmeshed with merits discovery, and again cannot be meaningfully developed without inquiry into the basic issues of the litigation In re Rail Freight Fuel Surcharge Antitrust Litig., 258 F.R.D. 167, 175 (D.D.C. 2009) (quoting Gray, 133 F.R.D. at 41). The In re Rail Freight court added that it will not accept defendants' glowing assessment of its own arguments -- namely, that class certification will fail or be substantially narrowedas a reason to bifurcate. Id. (citing to Intervet, Inc. v. Merial Ltd., No. 06-CV-658, 2008 U.S. Dist. LEXIS 45381, 2008 WL 2411276, at *2 (D.D.C. June 11, 2008), as declining to bifurcate privilege issue from merits based on movant's assessment of its own arguments). Where Defendants arguments here glow similarly, this Court should similarly reject such arguments. C. Defendants Position Regarding The Scope of Discovery.

Defendant anticipates that it will propound discovery regarding such areas as: (1) the circumstances surrounding Plaintiffs alleged injuries; (2) Plaintiffs knowledge regarding the risks associated with playing sports, including the risk of sustaining concussions; (3) the nature

Defendants failure to identify solely merits related discovery raises questions regarding its motivation for insisting on bifurcation. See Scott S. Partridge, Some Practical Considerations for Defending and Settling Products Liability and Consumer Class Actions, 74 Tul. L. Rev. 2125, 2162 (2000) (Of course, if a defendant has an especially weak case on the merits and does not wish to open itself up for any discovery, it may be better to bifurcate discovery and attempt to defeat class certification based on class certification discovery alone.).

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and extent of Plaintiffs alleged injuries; and (4) sports injury treatment protocols and procedures in place at Plaintiffs respective colleges. In order to ensure that a class certification decision is issued as soon as practicable, the NCAA proposes giving priority to discovery regarding the threshold question of whether Plaintiffs and their counsel can satisfy each of the requirements under Fed. R. Civ. P. 23 for either of their two proposed classes or the proposed Defendant class. In opposing the NCAAs suggested approach to discovery, Plaintiffs flatly misrepresent the NCAAs position. The NCAA is not proposing strict bifurcation of discovery. Rather, the NCAA merely suggests that priority be given to discovery that will permit a decision on class certification at an early practicable time, as required under Rule 23. Fed. R. Civ. P.

23(c)(1)(A). This approach is consistent with case law inside and outside this circuit. See Damasco v. Clearwire, 662 F.3d 891, 896-97 (7th Cir. 2011) (Although discovery may in some cases be unnecessary to resolve class issue, . . . in other cases a court may abuse its discretion by not allowing for appropriate discovery before deciding whether to certify a class . . .) (citations omitted); Heerwagen v. Clear Channel, 435 F.3d 219, 233 (2d Cir. 2006) (Discovery is often appropriate on class certification issues . . . The amount of discovery is generally left to the trial courts considerable discretion.); see also Fed. R. Civ. P. 23, notes to 2003 Amendment ([I]t is appropriate to conduct controlled discovery into the merits, limited to those aspects relevant to making a certification decision on an informed basis.); Manual for Complex Litigation, Fourth 21.14 (discussing the appropriateness of phased discovery). There are a number of significant issues that will need to be decided at the class certification stage. Certification requires Plaintiffs to prove the existence of questions of law or fact common to the classes, but the Complaint includes personal injury and fraudulent concealment claims, which will necessarily involve individualized inquiries into numerous

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factual issues, e.g., the circumstances surrounding each Plaintiffs alleged injury, each Plaintiffs knowledge regarding concussion risks and each Plaintiffs alleged reliance on the NCAAs supposed fraudulent concealment of concussion information. Plaintiffs must also prove that their claims are typical of those of the classes. See Fed. R. Civ. P. 23(a). Named Plaintiffs adequacy to serve as class representatives will also need to be rigorously analyzed, as will the relevant requirements under Rule 23(b), including predominance, superiority and manageability. Id. Plaintiffs also seek to certify a defendant class, consisting of [t]he NCAA and all members of the NCAA that have sports teams in which student-athletes participate. [Corrected] Consolidated Class Action Compl. 122. This not only raises a host of individual issues and manageability problems, but significant due process concerns, as Plaintiffs seek certification under Rule 23(b)(2), which does not permit opt outs. See Fed. R. Civ. P. 23(b)(2); see generally Henson v. East Lincoln Township, 814 F.2d 410, 413-14 (7th Cir. 1987) (holding Federal Rules did not permit certification of a defendant class under Fed. R. Civ. P. 23(b)(2)); Ameritech Benefit Plan Comm. v. Commun. Workers of Am., 220 F.3d 814, 820 (7th Cir. 2000) (Defendant classes, initiated by those opposed to the interests of the class, are more likely than plaintiff classes to include members whose interests diverge from those of the named representatives, which means they are more in need of the due process protections afforded by (b)(3)s safeguards. [A] defendant class is normally impermissible under Rule 23(b)(2).); Pabst Brewing Co. v. Corrao, 161 F.3d 434, 439 (7th Cir. 1998) (This court . . . has had occasion to note that the due process rights of unnamed class members of a defendant class are entitled to special solicitude, and their due process interests preclude altogether a defendant class under Rule 23(b)(2).). Giving priority to discovery regarding the threshold question of whether Plaintiffs can satisfy Fed. R. Civ. P. 23 would allow the Parties to fully and fairly explore these

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issues. The NCAA objects to Plaintiffs baseless attack on its motive for proposing that discovery initially focus on issues related to certification and merits issues that inform the class decision. It is entirely reasonable to prioritize discovery related to the threshold certification issue before delving into merits discovery as a denial of certification or a decision to narrow the class definition or class period may significantly reduce the scope of merits-related discovery. It would be premature to permit full discovery on merits issues such as Plaintiffs anticipated discovery subjects when the Courts certification decision could affect the scope of inquiry into some or all of these issues. The NCAA recognizes that there may be some overlap between discovery relevant to the issues of class certification and to the merits of the claims asserted in the complaint. Under U.S. Supreme Court and Seventh Circuit precedent, conducting discovery focused on class issues and such merits issues as inform the class decision is entirely appropriate. See Wal-Mart v. Dukes, 131 S. Ct. 2541, 2551 (2011) (rigorous analysis of Rule 23 prerequisites frequently will entail some overlap with the plaintiffs underlying claim); Szabo v. Bridgeport Machines, 249 F.3d 672, 676 (7th Cir. 2001) (Before deciding whether to allow a case to proceed as a class action, therefore, a judge should make whatever factual and legal inquiries are necessary under Rule 23. . . . [I]f some of the considerations under Rule 23(b)(3) . . . overlap the merits . . . then the judge must make a preliminary inquiry into the merits.). The NCAA agrees to work

cooperatively and in good faith with Plaintiffs to resolve any disputes regarding the scope of discovery in accordance with its obligations under the Federal Rules of Civil Procedure and the Local Rules for the Northern District of Illinois.

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IV.

REMAINING DISCOVERY Given the cases infancy, neither party has propounded document requests or

interrogatories. A. Proposed Discovery Schedule

The Parties propose the following timeline for completion of fact and class certification expert discovery: 1. Exchange of Rule 26(a)(1) disclosures: February 6, 2012; 2. Deadline for completion of fact discovery: October 9, 2012 3. Plaintiffs motion(s) for class certification, together with any expert reports in support of Plaintiffs motion for class certification, shall be filed and served on or before October 9, 2012. To the extent Plaintiffs identify any experts in support of their motion, Defendant shall have until November 23, 2012 or 45 days after service of Plaintiffs motion(s) for class certification, whichever is sooner, to take the depositions of the experts. 4. Defendants opposition to Plaintiffs motion(s) for class certification, together with any expert reports in support, shall be served on or before December 8, 2012 or 60 days after service of Plaintiffs motion(s) for class certification, whichever is sooner. To the extent Defendant identifies any experts in support of its opposition, Plaintiffs shall have until January 22, 2013 or 45 days after service of Defendants opposition, whichever is sooner, to take the depositions of the experts. 5. Plaintiffs reply in support of their motion for class certification, together with any rebuttal expert reports, shall be due February 6, 2013 or 60 days after service of Defendants opposition, whichever is sooner. To the extent Plaintiffs identify any experts in rebuttal, Defendant shall have until February 21, 2013 or 15 days after service of Plaintiffs reply, whichever is sooner, to take the depositions of the rebuttal experts. 6. Within 30 days of the Courts decision on Plaintiffs motion for class certification, the parties shall confer in good faith regarding any remaining discovery to be conducted in light of the Courts decision, as well as deadlines for dispositive motions, service of Rule 26(a)(2) expert reports, and the pre-trial order. V. TRIAL Plaintiffs have requested a jury trial. At this time, Plaintiffs estimate that the jury trial would take approximately three weeks for Plaintiffs to present their case in chief. Defendant estimates that should the case go before a jury, its defense of Plaintiffs individual claims would 12
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take approximately two to four weeks, and the trial of the claims of the members of the proposed classes would take several years at a minimum. VI. CONSENT TO PROCEED BEFORE A MAGISTRATE JUDGE At this time, the parties do not consent to proceed before a Magistrate Judge. VII. STATUS OF SETTLEMENT DISCUSSIONS At this time, the parties have not conducted any settlement discussions and do not request a settlement conference.

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Date: January 13, 2012

Respectfully submitted, By:/s/ Elizabeth A. Fegan Elizabeth A. Fegan Daniel J. Kurowski HAGENS BERMAN SOBOL SHAPIRO LLP 1144 W. Lake St., Suite 400 Oak Park, IL 60301 708.628.4960 708.628.4950 (F) beth@hbsslaw.com dank@hbsslaw.com Steve W. Berman (Lead Trial Attorney) HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Ave., Suite 3300 Seattle, WA 98101 206.623.7292 206.623.0594 (F) steve@hbsslaw.com Joseph J. Siprut (Lead Trial Attorney) SIPRUT PC 122 South Michigan Ave., Suite 1850 Chicago, Illinois 60603 312.588.1440 312.878.1342 (F) jsiprut@siprut.com Interim Lead Counsel By: /s/ B. John Casey Sean M. Berkowitz (Lead Trial Attorney) Mark S. Mester (Lead Trial Attorney) B. John Casey Johanna M. Spellman LATHAM & WATKINS LLP 233 South Wacker Drive, Suite 5800 Chicago, IL 60606 312.876.7700 312.993.9767 (F) sean.berkowitz@lw.com mark.mester@lw.com john.casey@lw.com johanna.spellman@lw.com Attorneys for Defendant 14

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CERTIFICATE OF SERVICE The undersigned, an attorney, hereby certifies that on January 13, 2012, a true and correct copy of the foregoing JOINT STATUS REPORT was filed electronically via CM/ECF, which caused notice to be served on all counsel of record.

___/s/ Elizabeth A. Fegan_________ Elizabeth A. Fegan

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