Snyder v. Phelps et al

Filing 107

MOTION for Reconsideration Regarding Limits On Discovery and motion to seal, Corrected by Fred W. Phelps, Sr, Westboro Baptist Church, Inc. Responses due by 8/23/2007 (Katz, Jonathan) (Sealed documents rec'd 8/6/07) Modified on 8/6/2007 (jnl, Deputy Clerk).

Snyder v. Phelps et al

Doc. 107

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND Baltimore Division ALBERT SNYDER, Plaintiff v. FRED PHELPS, et al, Defendant. : : : : : : : : :

Civ. No. 1:06-cv-01389-RDB

:

DEFENDANTS' NOTICE AND MOTION TO FILE DOCUMENTS UNDER SEAL Defendants Fred W. Phelps, Sr., and Westboro Baptist Church (collectively, Defendants), respectfully move, for the following grounds, to file the following documents ­- being hand-delivered on August 6, 2007 -- under seal: Defendants' Motion To Reconsider Limits On Discovery, And Motion For Limited Extension Of Discovery, together with the attachments thereto (Dr. Blumberg's IME report and excerpts from Plaintiff's deposition): 1. The Court previously issued a confidentiality Order in this civil action; 2. On August 3, 2007, pro se Defendant Shirley PhelpsRoper e-mailed Plaintiff's counsel Sean Summers that she would file a similar motion under seal, unless Mr. Summers agreed to filing said document without being sealed. 3. Mr. Summers replied, by e-mail, to file said document under seal. 1
Dockets.Justia.com

4.

Consequently, this Motion is being filed due to Plaintiff's desire for ongoing confidentiality in relation to the Confidentiality Order.

5.

A full copy of said Motion, with full attachments, is being filed and mailed within twenty-four hours of the date of this Notice to Seal.

WHEREFORE, Defendants respectfully move for leave to file under seal their Motion To Reconsider Limits On Discovery, And Motion For Limited Extension Of Discovery,

Respectfully submitted, ___/s/__________________________ Jonathan L. Katz D.Md. Bar No. 07007 1400 Spring St., Suite 410 Silver Spring, MD 20910 Ph: [phone] Fax: [phone] [e-mail]

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CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served by first-class mail, postage-prepaid, on August 6, 2007, to: Sean E. Summers, Esq. (also system) Paul W. Minnich, Esq. Rees Griffiths, Esq. Craig Tod Trebilcock, Esq. by the CM/ECF filing

Becky Phelps-Davis (by mail only) 1216 Cambridge Topeka, KS 66604 Shirley Phelps-Roper (by mail only) 3640 Churchill Road Topeka, KS 66604 ____/s/_____________________________ Jonathan L. Katz

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