[SBXVII]

This fan also makes some decent points:

Nice find.

I'm looking at the docket of the White lawsuit:

http://dockets.justia.com/docket/min...cv00906/57169/

I see a Stipulation of Dismissal on August 4. Then I see what seems to be a court ordered dismissal on August 11.

There seems to be 2 conflicting views. The NFLPA says Judge Doty rejected the stipulation and ordered the dismissal using narrower language. The NFL says the stipulation was valid and the court order was simply an administrative note. It's hard to know which one it is, but Judge Doty is the same judge for this new collusion lawsuit.

Perhaps, the answer lies in the fact that the broad language is conspicuously missing from the CBA. In the previous CBA, the stipulation was incorporated by reference into the CBA. This didn't happen in the new CBA, which uses the narrower language, so that might be a sign that the NFLPA is correct.

Let's assume the stipulation is valid. The "all unknown claims" language is definitely binding if the NFLPA intentionally agreed on a settlement for all unknown claims. If you look at the docket, the White case was filed in 1992, and the NFLPA takes any chance they can get to reopen it. That makes it hard to argue that the NFLPA specifically meant "all unknown claims", i.e. any possible collusion claim.

The "unknown claims" language does not bar a claim, if it can be shown that the unknown claims were not within the contemplation of the parties when the settlement was agreed upon. The question is: At the time of the settlement, could the NFLPA have contemplated the collusion in question?

That basically goes back to what I said in my previous post. Are the current collusion claims related to the collusion claims from the Brady or White lawsuits?