NFLPA Seeks Pre-Motion Conference With NFL Instead Of Filing Injunction

BOSTON (CBS) -- One way or another, the NFLPA wants the Tom Brady matter settled before Sept. 4.

Attorney Jeffrey Kessler wrote to New York judge Richard Berman on Friday, informing him that "submit this letter to jointly request a pre-motion conference regarding the parties' anticipated cross motions to vacate and confirm the July 28, 2015 arbitration award issued by NFL Commissioner Roger Goodell."

"The NFLPA and Mr. Brady had intended to file a motion for a temporary restraining order or a preliminary injunction," Kessler wrote. "However, the parties met and conferred and have agreed that a final resolution of this matter prior to the commencement of the 2015 NFL regular season would be in everyone's best interest."

Read: NFLPA's Full Request to Expedite Tom Brady Decision

The letter calls for the NFL and NFLPA to file their cases on Aug. 7, with the parties filing oppositions to each other's papers on Aug. 14. Then, "the parties would confer with the Court to set a hearing for oral argument on a date convenient to the Court that would enable a decision to be rendered by September 4, when Mr. Brady's team must prepare for its first regular-season game."

The letter notes that no discovery period would be necessary, and that the NFLPA plans to file a public "Answer and Counterclaim" on Friday.

The letter also seeks a confidentiality agreement which would keep certain material from becoming public knowledge.

"The NFL does not oppose this request," the letter states.

In its initial filing with the District Court in Minnesota on Wednesday, the NFLPA wrote that it intended to "shortly file a Motion for Preliminary Injunction or, in the Alternative, for Expedited Disposition so that relief can be granted prior to September 4, 2015."

On Thursday, Judge Berman told both parties to "actively begin to pursue a mutually acceptable resolution of this case" as well as a suggestion to "tone down their rhetoric."

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