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His desire for a contract befitting his back-to-back 100-catch seasons and stellar play is hampered by all the health and legal issues surrounding the Broncos' enigmatic star.
Will he return from hip surgery the same player who averaged 103 receptions, 1,295 yards and seven TDs each of the last two seasons?
And will he even be available for a full season?
Although the league decided Marshall won't face a suspension over his arrest in Atlanta this spring for fighting with his new fiancee, Marshall faces a trial later this summer on two misdemeanor battery charges stemming from an altercation with his former girlfriend.
The outcome of that case could subject Marshall to punishment from the NFL even though it was part of what triggered his summons to commissioner Roger Goodell's office last summer, when Marshall was suspended for the season opener and fined two paychecks after a series of police-related incidents involving his former girlfriend.
Marshall caught 104 passes for 1,265 yards and six TDs last season. But he dropped 18 on-target passes, something he blamed on the nerve damage in his right arm, which he said he put through a television set while horsing around with his brother a year ago in the offseason.
The Broncos are off until training camp in late July. If Marshall is still on the team, he could become their first camp holdout since Ashlie Lelie in 2006. Lelie forced a trade to Atlanta, which gave Marshall his chance to begin making his mark in Denver.
[Associated Press;
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