IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

USA FOOTBALL, INC.,

Plaintiff,

v.

FFWCT, LLC; USE FLAG, LLC; AND 

TRAVIS BURNETT,

Defendants.

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Civil Action No. 4:23-cv-00516-ALM

DECLARATION OF ANNE RICCHIUTO

1. My name is Anne Ricchiuto. I am of legal age and have never been convicted of any 

felony or crime involving dishonesty.

2. I am authorized to sign this declaration as an attorney at Peele Law Group, PC, which is 

counsel of record for USA Football in the above-captioned litigation (the “Action”). I 

make this declaration of my own personal knowledge. If called as a witness, I could and 

would competently testify to the truth of the matters asserted herein.

3. In my capacity as counsel for USA Football, I am familiar with the records and the type 

of records that have been served by and on USA Football during the litigation of the 

Action by personnel within the appropriate offices and departments of Peele Law Group 

and in the normal course of Peele Law Group’s work as counsel for USA Football. The 

matters stated herein are true and correct to the best of my knowledge and belief, based 

upon records and information kept in the normal course of business available at this time.

4. The information in this declaration is taken from Peele Law Group’s business records. 

Those records are: (a) made at or near the time of the occurrence of the matters recorded 

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2

by persons with personal knowledge of the information in the business record, or from 

information transmitted by persons with personal knowledge; (b) kept in the ordinary 

course of Peele Law Group’s regularly conducted business activities; and (c) within the 

regular practice of Peele Law Group to make such records. The records attached to this 

declaration are true and correct copies of the originals or exact duplicates of the originals. 

I have personally reviewed the attached records, and I make this affidavit from a review 

of those business records. 

5. A true and accurate copy of USA Flag’s November 16, 2023 Responses to Request for 

Production of Documents is attached hereto as Exhibit A. 

6. USA Flag did not produce financial information for USA Flag, Inc., although Travis 

Burnett testified that it does exist. This issue was included within a discovery letter I sent 

to counsel for USA Flag on April 24, 2024. A true and accurate copy of that discovery 

letter is attached hereto as Exhibit B.

7. A true and accurate copy of USA Flag’s April 26, 2024 Responses to Requests for 

Production of Documents is attached hereto as Exhibit C. 

8. On April 1, 2024 USA Football served written objections to USA Flag’s Rule 30(b)(6) 

Deposition Notice. A true and accurate copy of USA Football’s Objections to Rule 

30(b)(6) Notice is attached hereto as Exhibit D. 

I declare under the laws of the United States of America that the foregoing statements are 

true and correct.

Executed this 5th day of July, 2024. 

 Signature: ___________________ 

 Name: Anne Ricchiuto

Title: Of Counsel, Peele Law Group

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