Snyder v. Phelps et al

Filing 61

Correspondence re: Feb. 23 conference call. (Attachments: # 1 Exhibit Ex. 1 - Plaintiff Jan. 26 Stipul.# 2 Exhibit Ex. 2- Def. stipul.# 3 Exhibit Ex. 3 - Parties' e-mails# 4 Exhibit Ex. 4 - Plaintiff's circled document.)(Katz, Jonathan)

Snyder v. Phelps et al

Doc. 61 Att. 2

IN THE UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND Baltimore Division ALBERT SNYDER, Plaintiff FRED W. PHELPS, SR., et al, Defendants. ) ) ) Civil Action No. 06-CV-1389-RDB ) ) ) )

STIPULATION AND CONSENT ORDER CONCERNING DISCOVERY By stipulation of the parties, this agreement shall govern the taking of depositions of defendant Fred W. Phelps, Sr. ("Phelps") and the corporate representative of defendant Westboro Baptist Church, Inc. ("Westboro"). 1. The parties by and through counsel conducted a scheduling conference with the Court on November 28, 2006. authorized the parties to begin discovery. 2. The parties have agreed that the depositions of defendant Phelps will be taken in Topeka, Kansas on March5, 2007. 3. 4. No counsel of record is admitted to practice law in Kansas. Neither plaintiff nor any of plaintiff's counsel are conducting business in Kansas at this time, or have any other contacts there, and will be appearing in Topeka, Kansas, for the limited purpose of taking this deposition.
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The Court

5.

Plaintiff and his counsel accepted Topeka, Kansas as the forum for deposing defendant Phelps solely to accommodate this defendant.

6.

Defendants agree that they will not use the occasion of plaintiff or any of plaintiff's counsel traveling to Kansas for this deposition as the occasion to serve process, summons, or any other kind of legal process on plaintiff or any of his counsel.

7.

Defendants agree that they will not use the occasion of plaintiff or any of plaintiff's counsel traveling to Kansas for this deposition as the occasion to claim jurisdiction by any court over plaintiff or plaintiff's counsel.

8.

Phelps-Chartered is a corporation engaged in the practice of law in Kansas. Phelps-Chartered is not a party to this case and does not appear before this Court. The attorneys employed by Phelps-

Chartered are not parties to this case and do not appear before this Court. Defendants and their counsel have conferred with the

attorneys of Phelps-Chartered, and those attorneys have all agreed not to serve legal process or claim jurisdiction on or against plaintiff or any of his counsel during or based upon their trip to Topeka, Kansas to depose defendant Phelps on March 5, 2007. Defendants so agree hereby through the signature of their counsel.

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BARLEY SNYDER LLC By: _________________________________________ Paul W. Minnich Rees Griffiths Sean E. Summers 100 East Market Street P.O. Box 15012 York, PA 17405-7012 [phone] & Craig T. Trebilcock Shumaker Williams PC 135 North George Street York, PA 17401 [phone]

MARKS & KATZ, LLC By: _________________________________________ 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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