Lind v. Selig - MLB's Answer

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PROSKAUER ROSE LLP Kathleen M. McKenna Andrew E. Rice Eleven Times Square New York, NY 10036-8299 Telephone 212.969.3000 Fax 212.969.2900 [email protected] [email protected] Attorneys for Defendants UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X

14-CV-09786 (PAC)(JLC) ECF CASE ANSWER TO FIRST AMENDED COMPLAINT

SYLVIA LIND,

Plaintiff,

v. OFFICE OF THE COMMISSIONER OF BASEBALL, an unincorporated association doing business as MAJOR LEAGUE BASEBALL, ALLAN H. “BUD” SELIG and FRANK ROBINSON;

Defendants.

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Defendants Office of the Commissioner of Baseball (“MLB”), Allan H. “Bud” Selig

(“Selig”) and Frank Robinson (“Robinson”) (collectively, the “Defendants”), by and through

their attorneys, Proskauer Rose LLP, for their answer and affirmative defenses to the First

Amended Complaint (the “Complaint”) filed by Plaintiff Sylvia Lind (“Lind” or “Plaintiff”),

state as follows:

Case 1:14-cv-09786-PAC Document 17 Filed 03/30/15 Page 1 of 29

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AS TO “PRELIMINARY STATEMENT”

1. Deny the allegations set forth in Paragraph 1 of the Complaint, except admit that:

Plaintiff began working for Major League Baseball Properties, Inc. on November 21, 1995;

Plaintiff is one of the highest ranking Hispanic females in a management position; and MLB has

not appointed a Hispanic female to an executive position.

2. Deny the allegations set forth in Paragraph 2 of the Complaint, except admit that:

Jimmie Lee Solomon (“Solomon”) is an African-American attorney whom MLB hired in 1991

as Director of Minor League Relations; and Plaintiff worked for Solomon for approximately 15

years.

3. Deny the allegations set forth in Paragraph 3 of the Complaint, except admit that

on or about June 4, 2012, Solomon separated from employment with MLB following the

expiration of his employment agreement; that Plaintiff was neither considered nor interviewed

for the position of Executive Vice President of Baseball Development; and that MLB Hall of

Fame legend Robinson succeeded Solomon as Executive Vice President of Baseball

Development in June 2012.


from July 2012 to the present, Robinson promoted Ben Baroody (“Baroody”), a white male born

in 1984 and a prior subordinate of Plaintiff, several times, and ultimately placed Baroody in

charge of plaintiff; and that Robinson would request that Plaintiff send him written updates.

5. Deny the allegations set forth in Paragraph 5 of the Complaint.


Plaintiff purports to bring this action to remedy discrimination on the basis of gender, age and


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national origin in violation of the New York State Human Rights Law (“NYSHRL”) and the

New York City Human Rights Law (“NYCHRL”), and that Plaintiff purports to seek injunctive

and declaratory relief, compensatory and punitive damages, and other appropriate and legal and

equitable relief.

AS TO “THE PARTIES”

7. Deny the allegations set forth in Paragraph 7 of the Complaint, except admit on

information and belief that Plaintiff is an American citizen and a Hispanic female, and that

Plaintiff resides in the State of New Jersey; and admit that Plaintiff is currently employed by

MLB as a Director, and that prior to February 1, 2015, Plaintiff was employed by MLB as

Director of Baseball Initiatives.


Defendant Office of the Commissioner of Baseball, doing business as MLB, is an unincorporated

association comprising thirty Major League baseball clubs; that the Office of the Commissioner

is the executive office that, inter alia, is ultimately responsible for the recruiting, hiring, training

and retention of MLB executives and managers; and that MLB’s office is located at 245 Park

Avenue in the Count of New York and City and State of New York.


Selig served as Commissioner (or acting Acting Commissioner) of MLB from September 7,

1992 through January 24, 2015 and is a citizen of the State of Wisconsin, and aver that the

responsibilities of the role of Commissioner are set forth in the Major League Constitution.

10. Admit the allegations set forth in Paragraph 10 of the Complaint, except aver that

Robinson served as MLB Executive Vice President of Baseball Development from June 2012


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until February 1, 2015, when he became Senior Advisor to the Commissioner and Honorary

American League President.

AS TO “JURISDICTION AND VENUE”


Plaintiff purports to invoke this Court’s jurisdiction pursuant to 28 U.S.C. §§ 1332(a)(1) and

(c)(1).


Plaintiff purports to base venue in the Southern District of New York pursuant to 28 U.S.C. §

1391(b)(2).


Plaintiff purports to invoke this Court’s jurisdiction pursuant to Title VII of the Civil Rights Act

of 1964, 42 U.S.C. § 2000e (“Title VII”), the Age Discrimination in Employment Act of 1967,

29 U.S.C. § 621 (the “ADEA”), and 28 U.S.C. §§ 1331 and 1343(a)(3), and purports to invoke

this Court’s supplemental jurisdiction over claims under the NYSHRL and NYCHRL pursuant to

28 U.S.C. § 1367.

14. Deny knowledge or information sufficient to form a belief as to the truth of the

allegations set forth in Paragraph 14 of the Complaint.



AS TO “PROCEDURAL AND ADMINISTRATIVE REQUIREMENTS”

16. Deny the allegations set forth in Paragraph 16 of the Complaint, except admit

that: Plaintiff filed a Charge of Discrimination with the United States Equal Employment


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Opportunity Commission (“EEOC”) in or about August 2014 and was assigned federal charge

number 520-2014-02288; the EEOC sent a “Notice of Right to Sue” to Plaintiff on or about

December 31, 2014; and the Complaint was filed within 90 days of the Notice of Right to Sue.


Plaintiff purports to amend her Complaint to add claims under Title VII.

AS TO “JURY DEMAND”

18. Admit that Plaintiff requests a jury trial in this matter, but deny that a jury trial is

warranted or that Plaintiff is entitled to any relief whatsoever.

AS TO “FACTS COMMON TO ALL COUNTS”

As to “Lind’s Background and Employment History with MLB”

As to “MLB Legal Department”


Plaintiff earned a J.D. degree from Fordham Law School in 1995 and Plaintiff began working as

Legal Supervisor at MLB Properties on November 21, 1995.


21. Deny the allegations set forth in Paragraph 21 of the Complaint, except admit on

information and belief that when hired, Plaintiff was the only Hispanic female with a law degree

in the legal department of MLB Properties.


Phil Kahn was a white male who was hired as a staff attorney in the legal department of MLB

Properties.


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As to “Transfer to Minor League Operations in MLB”


in or around June 1997, Plaintiff responded to an internal MLB job posting and was hired by

Solomon (also an attorney) to the position of Supervisor of Minor League Operations in the

Office of the Commissioner.





during the time that Plaintiff worked as Supervisor of Minor League Operations, the Futures

Game was created, and that during her tenure at MLB, Plaintiff has had certain job duties related

to the Futures Game.


on or around March 31, 2000, Plaintiff was promoted to Manager of Minor League Operations

within MLB, in which role her responsibilities included presiding over Farm Directors’

Meetings, reviewing ownership transactions and relocations of Minor League Clubs,

administering the Player Development Contract reaffiliation process, serving as liaison with

Minor League Baseball, and maintaining relationships between Major League Clubs and their

Minor League affiliates.


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30. Admit on information and belief the allegations set forth in Paragraph 30 of the

Complaint.


Solomon was an Executive Vice President during 2005.

As to “Involvement in New Project Initiatives”


the Urban Youth Academy in Compton opened in 2006, and admit on information and belief that

Plaintiff was involved in the planning process for the Academy.


in late 2006, Plaintiff participated in the creation of the Civil Rights Game, a series of events

intended to celebrate people who perpetuated the spirit of the Civil Rights movement, that Selig

approved the concept and the first Civil Rights Game took place in 2007, and admit on

information and belief that in 2007 Plaintiff and Pat Scott also performed certain duties with

respect to Minor League operations.



As to “Hiring of Ben Baroody”


allegations set forth in Paragraph 35 of the Complaint, except admit that prior to the 2009 Civil

Rights Game in Cincinnati, Ohio, Pat Scott went out maternity leave.


Baroody is a white male born in 1984, and that in September 2010, Baroody was promoted to the


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position of Coordinator in Minor League Operations to replace Pat Scott, who left MLB shortly

after returning from maternity leave.


in 2010, Solomon became Executive Vice President of the newly created Baseball Development

department and that Plaintiff was not considered for this position.




allegations set forth in Paragraph 39 of the Complaint, except admit that Plaintiff was Director of

Baseball Development during 2012.

As to “Jimmie Lee Solomon Fired – Frank Robinson Hired”


on or about June 4, 2012, Solomon separated from employment with MLB following the

expiration of his employment agreement.

41. Admit on information and belief the allegations set forth in Paragraph 41 of the

Complaint.


Plaintiff had reported to Solomon for many years and that Plaintiff was not considered for,

discussed with respect to or offered Solomon’s previous position.

As to “Hall of Famer Frank Robinson Replaced Jimmie Lee Solomon”

43. Admit the allegations set forth in Paragraph 43 of the Complaint.


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As to “June 2012 – Initial Working Relationship with Frank Robinson”


during All-Star Week in 2012 in Kansas City, Robinson asked Plaintiff to handle various matters

consistent with her job responsibilities and, on information and belief, Pat Hemm was working

with the Commissioner.



Baroody was reassigned from Baseball Operations to Baseball Development.





during the first several months of Robinson’s tenure as Executive Vice President of Baseball

Development, he held conversations concerning the future of the department and decided that all

staff members in the department would report directly to him.



Robinson requested written status updates from all staff members reporting to him.



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Robinson asked Plaintiff’s opinion of how Baroody had been performing thus far, and Plaintiff

responded that Baroody was intelligent and hard-working but had some things to learn.

As to “Plaintiff’s First Written Evaluation from Mr. Robinson”


in or around January 2013, Robinson met with Plaintiff in her office and provided her with a

written evaluation of her performance, and deny knowledge or information sufficient to form a

belief as to the truth of the allegations concerning Plaintiff’s alleged reaction to the evaluation.


Plaintiff met with Robinson and Ray Scott, Senior Vice President of Human Resources,

concerning the evaluation, and that neither Scott nor any member of the Human Resources

department had been present at discussions of Plaintiff’s prior evaluations.




in or around August 2013, after the Civil Rights Game was held, Robinson told Lind that things

had generally gone well, but aver that Robinson also criticized Plaintiff’s performance with

respect to the Game.


Robinson requested that Lind write a memorandum concerning the 2013 Civil Rights Game, and

that Lind complied, although not to Robinson’s specifications.


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As to “Unwarranted Reassignment of Plaintiff’s Duties and Responsibilities”


in or around September 2012, Robinson informed Plaintiff that he was reorganizing the Baseball

Development department, in a meeting at which Ray Scott was present.


shortly after the 2012 Futures Game, Robinson informed Plaintiff that her responsibilities going

forward would be limited to the Civil Rights Game, and that the Futures Game was being

transferred to Baroody; and admit that Baroody later assumed control over the Urban Youth

Academies.


Plaintiff expressed to Robinson her disappointment at the reassignment of her duties, that she felt

that she had come up with the idea of the Futures Game and that it was unfair to take the Game

away from her.


Robinson told Plaintiff he would think about the Futures Game and ultimately told her that his

decision was final.


Baroody e-mailed Plaintiff regarding his presentation on the Futures Game.


As to “Unsubstantiated Allegations of Plaintiff’s Job Performance”


on one occasion, Robinson informed Plaintiff that others had commented about her drinking and


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missing meetings at the Winter Meetings, and that when Plaintiff denied this, Robinson said,

“Never? That’s an awful long time.”



As to “Mr. Robinson’s Directive to Work with His Daughter (Non-MLB Employee)


71. Admit the allegations set forth in the first sentence of Paragraph 71 of the

Complaint, except admit on information and belief the allegations set forth in the second and

third sentences of Paragraph 71 of the Complaint.


73. Deny the allegations set forth in Paragraph 73 of the Complaint, except admit the

second sentence of Paragraph 73 of the Complaint, admit that Nichelle Robinson (“Nichelle”)

requested changes to a form invitation letter that Plaintiff provided, and admit that Morgan

Freeman, Carlos Santana, and Muhammad Ali had in previous years accepted the award now

being presented to Berry Gordy (“Gordy”).




allegations set forth in Paragraph 75 of the Complaint, except deny the third sentence of

Paragraph 75 of the Complaint.


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Robinson told Plaintiff that Nichelle should be the contact person for Gordy.


79. Deny knowledge or information sufficient to form a belief as to the truth of

allegations set forth in Paragraph 79 of the Complaint, except deny that Nichelle acted as though

she was Plaintiff’s supervisor, and admit that there were e-mails concerning Plaintiff’s

conversations with Nansci Neiman-LeGette, and respectfully refer the Court to those e-mails for

their content.


As to “Plaintiff’s Second Evaluation from Robinson”


on or around February 18, 2014, Robinson and Plaintiff had a brief discussion about Plaintiff’s

performance, prior to Robinson’s provision of a written evaluation of Plaintiff’s performance for

2013.


Robinson told Plaintiff that he had seen limited improvement in her performance and that

Plaintiff needed to improve her communication, in part because others had told Robinson that

Plaintiff failed to respond promptly to messages.


Robinson told Plaintiff on several occasions that she needed to communicate better with


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Baroody, and that Plaintiff told Robinson that she felt Baroody failed to communicate well with

her.


Robinson informed Plaintiff in or around January 2014 that Baroody was being promoted and

that Plaintiff would be reporting directly to Baroody, that Plaintiff expressed displeasure at this

decision, and that Robinson told Plaintiff that he was not going to fire her.

As to “Plaintiff’s Second Written Evaluation”


on or around March 17, 2014, Plaintiff received notice that she was required to comment on her

written performance appraisal, and deny knowledge or information sufficient to form a belief as

to the truth of the allegation that Plaintiff refused to respond to the review until she had consulted

with counsel.


Plaintiff submitted the quoted language (with minor distinctions) in response to her written

evaluation on or about April 6, 2014.


Ron Rydell, MLB Director of Organization, Development and Training within Human

Resources, set up a one-on-one meeting with Plaintiff to discuss the concerns she raised in

response to her evaluation.




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As to “April 28, 2014 – Meeting Concerning Retaliatory Disciplinary Action”






Plaintiff copied Robinson and Baroody on an email that Plaintiff sent to Karen Chatman on April

16, 2014.




As to “April 29, 2014 – Rydell’s Inappropriate and Unprofessional Slanderous Comment”









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As to “May 20, 2014 – Follow up Meeting – Robinson’s Blatant Discriminatory Remark”


allegations set forth in Paragraph 102 of the Complaint, except admit that on or about May 20,

2014, Robinson met with Plaintiff as well as Baroody and Rydell to discuss Plaintiff’s 2013

performance evaluation.



that Robinson addressed several topics during the meeting including his disagreement with

Plaintiff about the previous oral evaluation, and that Robinson told Plaintiff that for all the time

that she had been at MLB, she should be “higher,” but that the problem was Plaintiff herself.


that Robinson expressed that he felt that he had invested in Plaintiff – which he had never done

for anyone in 60 years – and tried to help her improve.


that Robinson tried to express that an employee’s gender was irrelevant to him and that being a

woman does not limit Plaintiff’s ability to do her job or do her job well, and that Robinson noted

that there were few people of color (i.e., African-Americans) in the building, including in the

intern pool.





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that Plaintiff was asked to respond to Robinson’s comments and Plaintiff stated that she did not

have anything to say, and Robinson responded with words to the effect that Plaintiff does not say

anything negative to him in person, but only later puts negative things in writing.


that early in the working relationship between Robinson and Plaintiff, Rydell told Robinson that

he should tell Plaintiff when he was unhappy with her work; that Robinson told Rydell that he

would not meet with Plaintiff every time he was unhappy; and that Robinson stated at the May

20, 2014 meeting that he would no longer have a conversation with Plaintiff alone.




As to “Second Retaliatory Act”


that on or about July 25, 2014, Plaintiff was randomly selected by an independent third party for

drug testing pursuant to MLB’s Drug Policy and Prevention Program for non-playing personnel.


that Plaintiff had never before been subjected to drug testing.




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As to “Facts Outlining Defendants [sic] Discriminatory Policies and Practices”



121. Admit the allegations set forth in Paragraph 121 of the Complaint, except aver

that Steve Gonzalez is currently MLB’s Senior Vice President and Deputy General Counsel,

Labor & Human Resources; deny knowledge or information sufficient to form a belief as to the

truth of the allegations regarding Baseball Advanced Media; and deny that Lou Melendez was

“encouraged to take early retirement.”



124. Admit that no Hispanic females hold the title of Vice President or above at MLB,

as set forth in Paragraph 124 of the Complaint, except admit on information and belief that no

Hispanic females have held such a title during Plaintiff’s tenure at MLB.



that when Robinson served as the first Vice President of On-Field Operations, he hired a white

male in his twenties; and that when that individual left to work for the Texas Rangers, Robinson

hired another white male in his twenties as a replacement.




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129. Deny the first sentence of Paragraph 129 of the Complaint, and deny knowledge

or information sufficient to form a belief as to the truth of the remaining allegations in Paragraph

129 of the Complaint, except admit that Selig sent Plaintiff a congratulatory letter in 2006

concerning her receipt of an award from “Entre Nosotras,” and respectfully direct the Court

thereto.


that Plaintiff had not received any formal disciplinary action at MLB prior to the April 2014

disciplinary action.

131. Decline to respond to the hypothetical statement set forth in the preamble of

Paragraph 131 of the Complaint, as it does not contain any factual allegations.

(a) Deny the allegations set forth in Paragraph 131, Subparagraph (a) of the

Complaint, except admit that Plaintiff has been given latitude to exercise professional discretion

throughout her tenure at MLB.

(b) Deny the allegations set forth in Paragraph 131, Subparagraph (b) of the

Complaint, except admit that Plaintiff was assigned as a liaison to two World Baseball Classic

(“WBC”) teams for 2012, and that Plaintiff had some involvement in the 2006 and 2009 WBCs.

(c) Deny the allegations set forth in Paragraph 131, Subparagraph (c) of the

Complaint, except admit that Plaintiff has interacted with Hispanic media outlets regarding the

Civil Rights Game.

(d) Deny the allegations set forth in Paragraph 131, Subparagraph (d) of the

Complaint.


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(e) Deny the allegations set forth in Paragraph 131, Subparagraph (e) of the

Complaint.

(f) Deny the allegations set forth in Paragraph 131, Subparagraph (f) of the

Complaint, except admit that Robinson told Plaintiff that her writing was poor, and deny

knowledge or information sufficient to form a belief as to the truth of the allegations regarding

the speech that Plaintiff allegedly wrote for Maya Angelou.

(g) Deny the allegations set forth in Paragraph 131, Subparagraph (g) of the

Complaint, except admit that Robinson had, on occasion, told Plaintiff that he liked to have her

at meetings.

(h) Deny the allegations set forth in Paragraph 131, Subparagraph (h) of the

Complaint.



AS TO “FIRST CAUSE OF ACTION”

“Gender Discrimination under 42 U.S.C. §2000e against BOC, Selig and Robinson”

134. Repeat and reallege their responses to paragraphs 1-133 of the Complaint as their

response to paragraph 134 of the Complaint.






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AS TO “SECOND CAUSE OF ACTION”

“Gender Discrimination under the Executive Law against BOC, Selig and Robinson”








AS TO “THIRD CAUSE OF ACTION”

“Gender Discrimination under the Administrative Code against BOC, Selig and Robinson”










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AS TO “FOURTH CAUSE OF ACTION”

“National Origin Discrimination under 42 U.S.C. §2000e Against BOC, Selig and Robinson”








AS TO “FIFTH CAUSE OF ACTION”

“National Origin Discrimination under the Executive Law Against BOC, Selig and Robinson”









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AS TO “SIXTH CAUSE OF ACTION”

“National Origin Discrimination under the Administrative Code Against BOC, Selig and Robinson”









AS TO “SEVENTH CAUSE OF ACTION”

“Age Discrimination under the Age Discrimination in Employment Act of 1967, 29 U.S.C. § 621, Against BOC, Selig and Robinson”









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AS TO “EIGHTH CAUSE OF ACTION”

“Age Discrimination under the Executive Law Against BOC, Selig and Robinson”








AS TO “NINTH CAUSE OF ACTION”

“Age Discrimination under the Administrative Code Against BOC, Selig and Robinson”










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AS TO “TENTH CAUSE OF ACTION”

“Retaliation under 42 U.S.C. §2000e Against BOC, Selig and Robinson”








AS TO “ELEVENTH CAUSE OF ACTION”

“Retaliation under the Executive Law Against BOC, Selig and Robinson”









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AS TO “TWELFTH CAUSE OF ACTION”

“Retaliation under the Administrative Code Against BOC, Selig and Robinson”









AS TO “PRAYER FOR RELIEF”

210. Deny that Plaintiff is entitled to any relief as requested in this section of the

Complaint and the subparagraphs contained therein, or to any relief whatsoever.

AS AND FOR A FIRST AFFIRMATIVE DEFENSE

211. The Complaint fails, in whole or in part, to state a claim upon which relief can be

granted or for which the damages sought may be awarded.

AS AND FOR A SECOND AFFIRMATIVE DEFENSE

212. Plaintiff’s claims may be barred, in whole or in part, by the applicable statutes of

limitations or filing periods.


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AS AND FOR A THIRD AFFIRMATIVE DEFENSE

213. Plaintiff’s claims are barred, in whole or in part, as to any matters for which

Plaintiff failed to satisfy the statutory and/or administrative prerequisites to commencing and

maintaining this action.

AS AND FOR A FOURTH AFFIRMATIVE DEFENSE

214. Plaintiff has not been damaged by any of Defendants’ actions.

AS AND FOR A FIFTH AFFIRMATIVE DEFENSE

215. If damaged, which Defendants expressly deny, Plaintiff has failed to make

reasonable and diligent efforts to mitigate damages.

AS AND FOR A SIXTH AFFIRMATIVE DEFENSE

216. The Complaint fails to state a claim upon which an award of punitive damages

can be granted.

AS AND FOR A SEVENTH AFFIRMATIVE DEFENSE

217. Plaintiff is not entitled to recover punitive damages because, at all relevant times,

Defendants engaged in good faith efforts to comply with all of their contractual and statutory

obligations.

AS AND FOR AN EIGHTH AFFIRMATIVE DEFENSE

218. Plaintiff is not entitled to attorneys’ fees and costs under some of the causes of

action as demanded in the Complaint.

AS AND FOR A NINTH AFFIRMATIVE DEFENSE

219. Defendants’ actions with respect to Plaintiff were taken for legitimate, lawful,

non-discriminatory and non-retaliatory reasons.


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AS AND FOR AN TENTH AFFIRMATIVE DEFENSE

220. Even if impermissible considerations were a factor in the challenged employment

actions, which Defendants expressly deny, the same actions would have been taken for lawful,

non-discriminatory and non-retaliatory reasons.

AS AND FOR A ELEVENTH AFFIRMATIVE DEFENSE

221. At all times relevant herein, including prior to the alleged discriminatory and

retaliatory acts referred to in the Complaint, Defendants have established and complied with

policies, programs, and procedures for the prevention and detection of unlawful discriminatory

and retaliatory practices.

AS AND FOR A TWELFTH AFFIRMATIVE DEFENSE

222. At all times relevant herein, including prior to the alleged discriminatory and

retaliatory acts referred to in the Complaint, Defendants exercised reasonable care to prevent and

promptly correct any discriminatory and retaliatory behavior, and Plaintiff unreasonably failed to

take advantage of the preventative and/or corrective opportunities or to avoid harm otherwise.

AS AND FOR A THIRTEENTH AFFIRMATIVE DEFENSE

223. Defendants’ liability and penalties, if any, should be mitigated by virtue of the

factors set forth in the New York City Administrative Code § 8-107(13)(d) and (e).

AS AND FOR A FOURTEENTH AFFIRMATIVE DEFENSE

224. Plaintiff’s claims for damages based upon emotional, mental or physical injuries

are barred by the exclusivity provisions of the applicable workers’ compensation laws.


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AS AND FOR A FIFTEENTH AFFIRMATIVE DEFENSE

225. The alleged harassing conduct about which Plaintiff complains consists of nothing

more than what a reasonable person would consider petty slights and trivial inconveniences.

Defendants reserve their rights to modify this Answer and/or to assert additional

affirmative defenses should they become aware of additional defenses during the course of

discovery, as set forth in Rule 8 of the Federal Rules of Civil Procedure.

WHEREFORE, Defendants demand judgment against Plaintiff dismissing the

Complaint in its entirety with prejudice, together with an award of reasonable attorneys’ fees, the

costs and disbursements of this action, and such other and further relief as this Court deems just,

proper and equitable.

Dated: March 30, 2015 New York, New York

PROSKAUER ROSE LLP

/s/ Kathleen M. McKenna_____________ Kathleen M. McKenna Andrew E. Rice 11 Times Square New York, New York 10036 Phone: (212) 969-3000 Fax: (212) 969-2900 Email: [email protected] [email protected]

Attorneys for Defendants


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Lind v. Selig - MLB's Answer

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