Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

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1 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA RODNEY HENRY, Civil Action No. 15-cv-5971 Plaintiff, Section "J" (2) v. NEW ORLEANS LOUISIANA SAINTS, L.L.C., Jury Trial Demanded MR. TOM BENSON, and MRS. GAYLE BENSON, Defendants. DECLARATION OF RODNEY HENRY The undersigned hereby declares and states that the following is true and correct: 1. I make this declaration of my own personal knowledge and am competent to testify regarding the matters set forth herein. 2. In or around March 1989, I began working for the New Orleans Saints as the Personal Assistant to the Owner, Mr. Tom Benson. 3. In or around late 2004, Mr. Benson gave me a copy of an August 23, 2004 Interoffice Memorandum to Mr. Dennis Lauscha from Ms. Sheila Palmisano (the Saints' former Director of Human Resources). A true and correct copy of the August 23, 2004 Interoffice Memorandum to Mr. Lauscha is attached hereto as "Exhibit 1." 4. After Hurricane Katrina hit New Orleans in August 2005, I temporarily moved to San Antonio along with Mr. Benson and continued working as his Personal Assistant. After living in San Antonio for several months, I resigned my position as Mr. Benson's Personal Assistant so that I could return to New Orleans and work on rebuilding my home. 5. On or around July 24, 2010, I returned to working for the Saints as Mr. Benson's Personal Assistant. On the day I returned to work, the Saints presented me with a substantial 1

2 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 2 of 32 number of documents to sign, including the attached documents totaling more than twenty pages. True and correct copies of the foregoing documents are attached hereto as "Exhibit 2." These documents include, among other things, (i) an "Agreement;"(ii) a "Confidentiality Agreement;" (iii) a "NFL Personal Conduct Policy Acknowledgement;" (iv) a "Substance Abuse Policy Acknowledgement;" and (v) an "Acknowledgment regarding the Business Ethics and Conflicts of Interest Policy of the National Football League." 6. The Saints never provided me with the above-referenced documents for which I was required to acknowledge receipt. 7. While employed with the Saints, I never once was informed of the existence of the National Football League Dispute Resolution Procedural Guidelines ("the Guidelines") attached to Mr. Pat McKinney's Declaration (Doc. # 5-2) nor was I ever provided with a copy of the Guidelines. I was unaware of the existence of the Guidelines during my entire employment with the Saints. 8. While employed with the Saints, I never was provided with the National Football League's Constitution and Bylaws ("NFL Constitution") or an explanation of the NFL Constitution. During my entire employment with the Saints, I was unaware of how to obtain a copy of the NFL Constitution. 9. In or around 2000, I received a Job Description for the Personal Assistant position from Ms. Jennie Guarisco, Mr. Benson's Executive Assistant. A true and correct copy of the Job Description is attached hereto as "Exhibit 3." 10. On or around January 23, 2014, Mr. Benson called me into his office and presented me with a document entitled "Employment Agreement of Rodney Henry." Mr. 2

3 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 3 of 32 Benson and I signed the Employment Agreement and he told me to make a copy for myself. A true and correct copy of the Employment Agreement is attached hereto as "Exhibit 4." 11. On or around September 8-9, 2010, and while working as Mr. Benson's Personal Assistant, Mr. Roger Goodell, the Commissioner of the NFL, was a personal guest of Mr. and Mrs. Benson for a Saints/Vikings game and sat in the Benson's suite at the Superdome. During the game, I waited upon the Bensons and Mr. Goodell, i.e., brought them food and drinks and helped with anything else they needed assistance with. 12. On another occasion (I cannot remember the exact date), Mr. Goodell visited New Orleans with his children. Shortly thereafter, Mrs. Benson had me bring beignets and a bag of wrapped gifts to Mr. Benson's plane for Mr. Goodell and his children. 13. In or around late-january 2013, and while working as Mr. Benson's Personal Assistant, Mrs. Benson asked me to deliver a king cake and a bag with wrapped gifts from Mr. and Mrs. Benson to Mr. Goodell. Mrs. Benson instructed me to deliver the gifts to the airport and leave them at General Aviation for Mr. Goodell to pick up. 14. On or around June 24, 2015, Mr. McKinney unexpectedly called me into a meeting and told me that my employment was terminated. Mr. Benson was not present during the termination meeting and at no time did Mr. Benson communicate with me regarding my termination or the basis for it. Pursuant to 28 U.S.C. 1746, I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on the 1 st day of March, S/ Rodney Henry Mr. Rodney Henry 3

4 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 4 of 32 Exhibit 1 to R. Henry Declaration (A-1)

5 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 5 of 32 Exhibit 2 to R. Henry Declaration (Ex. A-2) HENRY_0001

6 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 6 of 32 HENRY_0002

7 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 7 of 32 HENRY_0003

8 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 8 of 32 HENRY_0004

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13 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 13 of 32 HENRY_0009

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19 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 19 of 32 HENRY_0015

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21 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 21 of 32 HENRY_0017

22 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 22 of 32 HENRY_0018

23 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 23 of 32 HENRY_0019

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26 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 26 of 32 HENRY_0022

27 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 27 of 32 HENRY_0023

28 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 28 of 32 HENRY_0024

29 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 29 of 32 HENRY_0025

30 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 30 of 32 Exhibit 3 to R. Henry Declaration (Ex. A-3)

31 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 31 of 32

32 Case 2:15-cv CJB-JCW Document 17-1 Filed 03/01/16 Page 32 of 32 Exhibit 4 to R. Henry Declaration (Ex. A-4)

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