Snyder v. Phelps et al

Filing 121

MOTION for Extension of Time to File SJ Motion and Jury Questionnaire by Fred W. Phelps, Sr, Westboro Baptist Church, Inc.. Responses due by 9/17/2007 (Katz, Jonathan)

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Snyder v. Phelps et al Doc. 121 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' CONSENT MOTION FOR AN ADDITIONAL BUSINESS DAY TO FILE SUMMARY JUDGMENT MOTION AND PROPOSED JURY QUESTIONNAIRE Defendants Fred W. Phelps, Sr., and Westboro Baptist Church (collectively, Defendants), respectfully move, by consent of all parties, for leave to have an additional business day, through September 4, 2007, to file their summary judgment motion and proposed jury questionnaire. On August 31, 2007, all parties consented to this motion via e-mail from Plaintiff's counsel Sean Summers, and by phone with pro se Defendant Shirley Phelps, who confirmed that pro se Defendant Rebekah Phelps similarly consents. The grounds for this Motion include that Defendants plan to file both of the above-listed documents under seal - so as to avoid any claim that the confidentiality order in this case has been violated. While it might have been possible for Defendants to file said documents electronically by the end of the night on August 31 (the current filing deadline), undersigned counsel did 1 Dockets.Justia.com not have such time availability to have those documents completed in time to have it received by the Court by courier on August 31. WHEREFORE, Defendants respectfully move to have until September 4, 2007, to file their summary judgment motion and proposed jury questionnaire. Respectfully submitted, ___/s/__________________________ Jonathan L. Katz D.Md. Bar No. 07007 1400 Spring St., Suite 410 Silver Spring, MD 20910 Ph: (301) 495-4300 Fax: (301) 495-8815 jon@markskatz.com 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served by first-class mail, postage-prepaid, on August 31, 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 3

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