Snyder v. Phelps et al

Filing 138

NOTICE by Fred W. Phelps, Sr, Westboro Baptist Church, Inc. Exceptions to Plaintiff's proposed jury questionnaire questions. (Katz, Jonathan)

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Snyder v. Phelps et al Doc. 138 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' OBJECTIONS TO PLAINTIFF'S PROPOSED QUESTIONS FOR JURY QUESTIONNAIRE Defendants Fred W. Phelps, Sr., and Westboro Baptist Church (collectively, Defendants), hereby object as follows to the jury questionnaire questions proposed by Plaintiff: Defendant object to all Plaintiff's questions for circumventing the purpose of a jury questionnaire in this civil action, which is to enable the parties to obtain information about the venire panel that would not be sufficiently possible merely through judge-directed jury selection. Defendants welcome and re-request having full or partial (e.g., if only for ten minutes) lawyer-conducted jury voir dire, which the Court rejected during a previous phone conference with the Court. However, to the extent that questions posed to the venire panel are going to carry the Court's imprimateur, rather than being presented directly by opposing counsel, then jury questionnaire questions should not be of the argumentative type proposed by Plaintiff that do little to nothing to provide information to the parties to assist in streamlining and 1 Dockets.Justia.com supplementing the voir dire process. To the extent that the Court keeps any of Plaintiff's proposed jury questionnaire questions, Defendants respectfully request that the jury questionnaire clearly designate which questions were submitted by the Defendants, which were submitted by the pro se defendants, and which were presented by Plaintiff. Respectfully submitted, MARKS & KATZ, LLC ___/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 Attorneys for Defendants Fred W. Phelps and Westboro Baptist Church 2 CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served by the CM/ECF filing system on September 18, 2007, to: Sean E. Summers, Esq. Paul W. Minnich, Esq. Craig Tod Trebilcock, Esq. 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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