http://sports.espn.go.com/nfl/columns/stor...&id=3462384
Larry Nemmers and the Buffalo Bills, 2002 to 2006
Circumstantial evidence: On Dec. 23, 2001, Nemmers worked the Falcons' 33-30 victory over the Bills in the Georgia Dome. His crew assessed 12 penalties for 95 yards against the Bills, compared to five penalties for 43 yards against the Falcons. Bills tight end Jay Riemersma disputed a critical pass-interference penalty called against him. "The guy I was blocking actually told me, 'You didn't hold me, I tripped,'" Riemersma told the Buffalo News.
Four referees have a longer game drought than this.