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No. 16-477


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oupreme Court of the aniteb Otate



         NEW JERSEY THOROUGHBRED
         HORSEMEN'S ASSOCIATION, INC.,
                                  Petitioner,
                      V.

NATIONAL COLLEGIATE ATHLETIC ASSOCIATION,
NATIONAL BASKETBALL ASSOCIATION, NATIONAL
FOOTBALL LEAGUE, NATIONAL HOCKEY LEAGUE,
OFFICE OF THE COMMISSIONER OF BASEBALL,
   doing business as MAJOR LEAGUE BASEBALL,


                       Respondents.



 On Writ Of Certiorari To The
United States Court Of Appeals
    For The Third Circuit



BRIEF FOR THE PETITIONER


EDWARD A. HARTNETT
  Richard J. Hughes
  Professor of Law
SETON HALL UNIVERSITY
  SCHOOL OF LAW
One Newark Center
1109 Raymond Boulevard
Newark, New Jersey 07102
(973) 642-8842


RONALD J. RIccIo
  Counsel of Record
ELIOTT BERMAN
MCELROY, DEUTSCH, MULVANEY
  & CARPENTER, LLP
1300 Mount Kemble Avenue
Morristown, New Jersey 07962
(973) 993-8100
rriccio@mdmc-law.com


             Counsel for Petitioner
New Jersey Thoroughbred Horsemen's Association, Inc.

            COCKLE LEGAL BRIEFS (800) 225-6964
            WWW.COCKLELEGALBRIEFS.COM

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