Snyder v. Phelps et al

Filing 126

MOTION to Seal Summary Judgment Motion by Fred W. Phelps, Sr, Westboro Baptist Church, Inc.. Responses due by 9/21/2007 (Katz, Jonathan)

Snyder v. Phelps et al

Doc. 126

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 DOCUMENT UNDER SEAL Defendants Fred W. Phelps, Sr., and Westboro Baptist Church (collectively, Defendants), respectfully move, for the following grounds, to file the following document ­- being hand-filed at the Court on September 4, 2007 -- under seal: Defendants' Summary Judgment Motion: 1. The Court previously issued a confidentiality Order in this civil action; 2. Plaintiff may argue that some of the contents of the attached proposed questionnaire questions arguably fall within the confidentiality order. 3. Consequently, this Motion is being filed due to Plaintiff's desire for ongoing confidentiality in relation to the Confidentiality Order. 4. A full copy of said proposed questionnaire is being filed and mailed within twenty-four hours of the date of this Notice to Seal. 1
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WHEREFORE, Defendants respectfully move for leave to file under seal their proposed jury questionnaire questions.

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 September 4, 2007, to: Sean E. Summers, Esq. (also system) Paul W. Minnich, 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 Honorable Richard D. Bennett (by hand) Baltimore Division 101 W. Lombard Street Baltimore, MD 21201 [phone] ____/s/_____________________________ Jonathan L. Katz

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