Kirk of the Hills Legal Docs

Here Comes The Judge!

Tulsa District 11 Judge: Jefferson D. Sellers
He is also handling the lawsuit against "OK-HB-1804" which punishes those who aid and abbet illegal immigrants, like landlords, employers. He is one of 14 District Judges for Tulsa County with 18 appointed "Special Judges" and 1 Associate District Judge.
The District Judges and Associate Judges are elected. Special Judges are hired. All elected Judges in Oklahoma run as nonpartisan.

Issues Before the Court

Official Court Docket
DateWhoIssueStatus
Aug 16, 2006 Kirk of the Hills Corp. vs PCUSA/EOP Breach of ContractEOP
May 29, 2007 EOP of PC vs Kirk Corp. CC #1 - Enforcement of Administrative Commission Reportdisposed
May 29, 2007 EOP of PC vs Kirk Corp. CC #2 - Declaratory Judgement granted
May 29, 2007 EOP of PC vs Kirk Corp. CC #3 - Breach of Fiduciary Duty dropped
May 29, 2007 EOP of PC vs Kirk Corp. CC #4 - Breach of Contract dropped

Kirk of the Hills News Stories

Layman Online Kirk may reconsider $1.75 million settlement
Layman Online Presbytery, PCUSA want spoils from Kirk’s givers
Layman Online Kirk-presbytery negotiations at risk but still move forward
Tulsa World Ruling clears way for Kirk of Hills deal
Layman Online Doubts raised over presbytery exec’s assurance in Kirk case The Layman
Layman Online Remaining steadfast on the Hill
Tulsa WorldPastors: No regrets Kirk of the Hills left denomination
NewsOK Oct 25 Tulsa church hopeful of retaining property
Tulsa World Kirk deal no longer is certain
Classical Presbyterian Blog Sauron..ahem...Louisville Enters the Fray!
Layman Online PCUSA lawyer clouds Kirk settlement proposal
Tulsa BeaconKirk of the Hills will buy its own building
PCUSA newsTulsa church approves buying back its property
Layman OnlineKirk's congregation votes to re-buy its own property
Tulsa World Church votes to buy its home
Tulsa World (long version) Church votes to buy back its property
Layman Online Kirk's session recommends rejecting property buyout
Tulsa World Local Briefs: Kirk of the Hills vote on buyback delayed
Christianity Today The rules in church property fights can change at the state border.
Mark D. Roberts Blog The PC(USA) and Church Property, Part 13
Tulsa Beacon Editorial Free the Kirk!
Layman OnlinePresbytery offers Kirk $1.75-million for property
Tulsa World Kirk of the Hills members weigh purchase offer
Kirk Tom's Report 1
KirkTom's Report 2
EOP Proposed Kirk of the Hills Settlement
Tulsa Beacon Editorial Kirk decision is simply wrong
GA Junkie Blog: Summary Judgment in the Kirk of the Hills Property Case
Reformed Pastor Blog: Decision Goes Against Tulsa Kirk
Kirk Member Letter: Kirk's ultimate commitment is to Jesus Christ
Tulsa World Kirk of Hills congregation faithful about future
KJRH news(2 NBC): South Tulsa church discusses future
Kirk of the Hills Church Kirk Press Release
Eastern Okla. Presbytery EOP Press Release
Tulsa World Story Kirk of the Hills Presbyterian loses property fight
Presbyterian OutlookOklahoma court upholds presbytery, PC(USA) in Kirk of the Hills case
Tom Gray-Letter to LaymanKirk of the Hills is 'far from defeated'
Church ExecutiveOklahoma court rules that Eastern Oklahoma Presbytery is legal owner of Tulsa church’s property
PCUSA newsOklahoma court rules presbytery is owner of Tulsa church's property
Christian Broadcasting NetworkTulsa Congregation Loses Property Battle
Church SolutionsMegachurch To Lose Building to Former Denomination, Court Says

Court Events

DateDescription
Mon Oct 23, 2005 14:00 Motion to Produce Records, Motion for Stay
Thur April 12, 2007 09:30 EOP's Motion to Compel
Thur Sep 20,2007 09:00 Motion to Compel
Thur Dec 20, 2007 Motion to Compel
Thur, Aug 28, 2008 9:00 AM Hearing on Summary Judgements

Legal Documents

Kirk's website has more legal documents: • Part 1& Part 2

Let's look at these together. Feel free to post comments. I add summaries to each document link, including your evaluations.

Interesting Quote: Kirk's Sur-Reply: "The very simple key to resolving the entire case is disaffiliation."

Interesting Quote: Kirk's Brief: "This Court should not be duped by the Defendant's litigation tactics."

Interesting Quote: EOP brief 1: "Kirk's Shell game" (Corp and Church separate).

  • Kirk's Petition to the Court - Aug 16, 2006 • → Presbylaw's Combined Petition & Response
    • Parties (EOP,PCUSA,Kirk Corp)
    • Facts Supporting Claims
      • 5-Kirk of the Hills is a corporation
      • 6-26 Kirk Bought Property A, B, C, & Personal
      • EOP/PCUSA have no legal, equitable or other interest in Kirk Property
      • 27-32 Rev. Ann Brizendine Affidavit of Trust on Kirk Property, Mar 6, 2006
      • 33-39 No trust or revoked
      • 40 - Kirk has Authority to buy sell, & manage, Property of Kirk
      • 41 - BOO is not governing
    • Declaratory Relief
      • No Trust
      • Attorney Fees and Costs
      • Other Just and Proper Relief
    • Quiet Title
  • PCUSA's Response - Dec 18, 2006 • → Presbylaw's Combined Petition & Response
    • Parties (EOP,PCUSA,Kirk Corp)
    • Facts Supporting Claims - Denied
    • Declaratory Relief - Denied
    • Quiet Title - Denied
    • Affirmative Defenses
      • Constitution of the Presbyterian Church (U.S.A.)
      • Administrative Commission
      • Hierarchical Deference
    • Counterclaim
    • Declaratory Judgment
    • Breach of Fiduciary Duty
    • Prayer For Relief
      • Dissmis Kirk's Petition
      • Declare Trust Exists
      • Kirk pays Rent, Damage, Decress of Value.
      • Convey Property to PCUSA
      • Attorney's Fee and Costs, & Other Relief
  • Kirk's Motion for Summary Judgment with Exhibits - Jan 22, 2007 • → Text Version
    1. Introduction
    2. Statement of Uncontroverted Material Facts
    3. Standards for Summary Judgment
    4. Arguments and Authorities
      1. This Court has jurisdiction to consider Plaintiff's claims
      2. This Court does not have jurisdiction to consider PC(USA)'s claims
      3. Plaintiff Corporation is entitled to judgment quieting its title to its real properties
      4. Plaintiff Corporation is entitled to judgment declaring its ownership of its personal property
      5. Plaintiff Corporation has not breached its fiduciary duty and is entitled to judgment on the counterclaim
      6. Plaintiff Corporation has rights under Oklahoma law
        1. Plaintiff Corporation is distinct from the Kirk of the Hill Church
        2. Plaintiff Corporation is not a member of PC(USA) or EOP
        3. Plaintiff Corporation is entitled to due process of law as to its properties
      7. Cimarron does not apply
    5. Conclusion
    6. Exhibits
      1. Exhibit A, "Articles of Incorporation"
      2. Exhibit A², "Certificate of Incorporation"
      3. Exhibit B, "Affidavit of Kyle Travis"
      4. Exhibit C, "Plat of Property"
      5. Exhibit D, "The Presbyterian Family Connections"
      6. Exhibit E, "Book Of Order 2005/2007 Excerpts"
      7. Exhibit F, "Affidavit of Rev. Ann Brizendine"
      8. Exhibit G, "Quit-Claim Deed Feb 8, 1969"
      9. Exhibit H, "General Warranty Deed March 14, 1978"
      10. Exhibit I, "Quit-Claim Deed Sept 8, 1995"
      11. Exhibit J, "Amended and Restated Certificate of Incorporation"
      12. Exhibit K, "Corporation Bylaws"
      13. Exhibit L, "Unanimous Consent to Action Taken in Lieu of a Special Meeting"
      14. Exhibit M, "Trustee Meeting Minutes, Tues, Aug 15, 2006"
      15. Exhibit N, "Companion to the Constitution"
      16. Exhibit O, "Affidavit, Glenn Elliott, Corporation Secretary"
      17. Exhibit P, "Affidavit, Lindsay H Fick, Clerk of the Session"
  • Eastern Oklahoma Presbytery's Request for Documents - Feb 5, 2007 • → Text Version
    • Definitions
    • Instructions
    • Interrogatories - #6
      1. Identify members (Jan 1 2005, Jan 1 2006, Aug 1 2006, Jan 1 2007
      2. Identify Personal Property
      3. State Factual Basis for EOP/PCUSA has no authority or interest in Property
      4. State Factual Basis for Renounced or Terminated
      5. Identify Lenders... with interest in Property
      6. Identify Other Parties with interest in Property
    • Request for Production - #94
      1. 1-2 Supporting Documents for Responses
      2. 3-13 Property Documents, Acquisition, Financing, Communication, Insurance, Title Opinions
      3. 14-15 Correspondence w/ EOP/PCUSA Jan 1, 2001-present
      4. 16-18 Certificate of Incorporation, Articles of Incorporation, Bylaws from 1961 to present & amendments
      5. 19-20 Employment Agreements: Tom Gray & Wayne Hardy
      6. 21 Membership Lists, Jan 1, 1961 to present.
      7. 22-26 List of Shareholders, Elders, Directors, Trustees, Officers of Kirk Corp.
      8. 27-56 Lists of Members, Shareholders, Elders, Directors, Trustees, Officers of Kirk of the Hills (United/Presbyterian) Church.
      9. 57-62 Lists of Members, Shareholders, Elders, Directors, Trustees, Officers of Kirk Foundation.
      10. 63-90 Minutes of Session, Cong Meeting, Shareholders, Elders, Trustees, Officers, Directors of Kirk of the Hills (United/Presbyterian) Church/Corp.
      11. 91-94 Property Documents - Mortgage, Pledge, Security
  • EOP's Administrative Report of Kirk of the Hills - Mar 6, 2007
    • Stated Supply Pastor & Moderator Appointed by EOP COM Aug 25, 2006
    • Kirk is in Schism
    • Pastors and Session violated PCUSA constitution by changing Articles and Bylaws.
    • Kirk is stifling opposition
  • PCUSA's Brief - In Support of Counter Motion for Summary Judgment - April 18, 2008
    • Cimarron has not been overruled
    • Oklahoma is a hierarchical deference state
    • PCUSA is "Hierarchical"
  • EOP's Brief 1 - In Support of Motion for Summary Judgment - April 25, 2008
    • Cimarron has not been overruled
    • Oklahoma is a hierarchical deference state
    • PCUSA is "Hierarchical"
    • Exhibits
      • A - Administrative Commission Report on Kirk Mar 6, 2007
      • B - Tom Gray Blog Comment 5:11 Aug 27, 2006
      • Background Info - Called meeting of EOP - Sept 5, 2006
      • Book of Order
      • M - Tom Gray Blog Comment 3:11 Aug 27, 2006
      • V - Tom Gray Blog Comment Aug 5, 2006
      • VV - EOP Meeting March 2, 1999
      • WW- EOP Meeting March 5, 2002
  • EOP's Brief 2 - Sur-Reply in Opposition to Plaintiff's Motion for Summary Judgment - April 25, 2008
    • Summary
      • Cimarron has not been overruled
      • Oklahoma is a hierarchical deference state
      • PCUSA is "Hierarchical"
    • Substantial Controversy
      • Kirk's Vote To Sever Relationship?
      • Kirk Corp is separate from Kirk Church?
      • PCUSA is a predecessor?
      • EOP's Failure to Controvert Facts?
    • Arguments
      • Original Articles of Incorporation & Bylaws create a perpetual relationship.
      • OK T18-S1127 cannot reduce liability by change in Articles.
      • Kirk Corp is Bound by PCUSA Constitution.
      • Property of Church are not separate from Kirk Corp.
      • Trust Was created.
      • Contractual relationship
      • AC Report will not violate The First Amendment.
      • EOP wants summary Judgment.
  • Kirk's Brief - Feb 29, 2008
    • Cimarron (1973) was no longer used by the OK Courts since Jones(1979).
    • Kirk Corporation is not a member of EOP/PCUSA only people
    • No trust exists now or ever
    • Due process required for Kirk corp.
    • Neutral Principles is Okla. Law
    • No Ecclesiastical Decision
    • EOP's AC acted without Consent. After disaffiliation.
    • Kirk paid for everything.
    • PCUSA has no standing only EOP
    • 37 Undisputed facts.
  • Kirks Exhibits 1 (brief pt 2)
    • Amended Articles of Incorporation.
    • Amended Certificate of Incorporation.
    • Corporation Bylaws
    • Unanimous Consent to Action Taken, In Lieu of a Special Meeting of the Board of Trustees
    • Affidavit on Trust Removal
    • Trustee Minutes
    • Affidavit of Pastor Tom Gray
    • Report of Independent Auditors on PCUSA
    • EOP Balance Sheet
  • Kirks Exhibits 2 (brief pt 3)
    • Magistrate's Decision: Hudson PC vs Eastminister Presbytery Oct 23 2007
    • Kirk Balance Sheet 2007
    • Warranty Deed Mar 3, 2005 - Roman Catholic
    • Warranty Deed May 16, 2000 - Roman Catholic
    • Warranty Deed Jan 29, 1983 - LDS
    • Warranty Deed Feb 20, 1980 - LDS
    • Quit-Claim Deed Feb 20, 1980 - LDS
    • NY - Presbytery of Hudson River vs. FPC of Ridgebury Aug 16, 2006
    • Affidavit Clerk of the Session - Kirk Aug 15, 2006
    • Unanimous Consent to Action Taken, In Lieu of a Special Meeting of the Session of Kirk of the Hills Corporation July 4, 2006
    • Exhibit B - Land Description
    • Companion to the Constitution
    • Book of Discipline of the United Methodist Church.
    • Real Estate Mortgage - Kirk w/ UPC in USA $75k Mar 30, 1971
    • Real Estate Mortgage - Presbytery of Tulsa w/ UPC in USA $100k Dec 14, 1964
    • Admin Comm Report on Kirk - Mar 6, 2007
    • Presbytery of Cimarron vs Westminster PC of Enid - "Journal Entry of Judgment"- Oct 4, 1974
  • Kirks Exhibits 3 (brief pt 4)
    • EE - Journal of 183rd GA - PC in the USA - Dec 1981
    • FF - Presbyterian Polity for Church Officers (2nd ED) pg 6
    • GG - UPC, Paola, KS v. Heartland Presbytery - Oct 18, 2004
    • HH - Church Property Resource - PCUSA
    • II - Kirk State Session Meeting, Tue, Aug 15, 2006
    • JJ - Kirk Congregational Meeting, Wed, Aug 30, 2006
    • KK - Kirk Congregational Meeting, Wed, June 28, 2006
    • LL - Congregational Bylaws of Kirk of the Hills June 28, 2006
    • MM - State of Defendant's Fact Which are Either Immaterial or to Which There is Substantial Controversy.
    • Pacific Reporter - AOG vs New Hope of Norman - July 17, 1979
    • Pacific Reporter - Presbytery of Cimarron vs Westminster PC of Enid
  • Kirks Exhibits 4 (brief pt 5)
    • Pacific Reporter - Daniels vs Union Baptists Association
    • Pacific Reporter - Fowler et all vs Bailey, et all
    • Pacific Reporter - Guinn vs Church of Christ of Collinsville, OK
  • Kirks Exhibits 5 (brief pt 6)
    • Pacific Reporter - Hadnot vs LDS, Chickasha
    • Supreme Court Reporter - Jones vs Wolf
    • Supreme Court Reporter - Maryland & Virginia Elership of COG vs COG at Sharpsburg
    • Pacific Reporter - Oaks Country Club vs FPC of Tulsa & Camp Loughridge
  • Kirk's Sur-Reply Brief
    • Summary: The very simple key to resolving the entire case is disaffiliation.
    1. Administrative Commission Had No Jurisdiction
      1. Disaffiliation by Kirk Terminated PCUSA Ecclesiastical Jurisdiction.
      2. Kirk Had the [ed: US] Constitutional Right to Disaffiliate from PCUSA
      3. Book of Order Does Not Prohibit Corporations or Congregations From Unilaterally Disaffiliating from PCUSA.
      4. Kirk's Corporation's Amendment of its Corporate Articles and Bylaws was Lawful
    2. There is No Trust Agreement Between Kirk Corporation and EOP/PCUSA.
    • Conclusion: Grant Kirk's Summary Judgment; Deny EOP/PCUSA (disputed facts)

Tuesday, February 27, 2007

Corrections Welcomed

Please email a comment for corrections or additions.

Court Time Line

Tulsa District Civil Court Docket for Kirk v. EOP
click for the official version (in legaleze)

DateWhoDescription
2008 Oct 24EOPProposed Journal Entry!
2008 Oct 16EOPDismissal without Prejudice Fiduciary Duty and Breach of Contract
2008 Oct 16KirkProposed Order and Motion to Reconsider
2008 Oct 16EOPProposed Journal Entry
2008 Oct 6CourtHearing Held - Scheduling Conference Nov 4
2008 Oct 3KirkNotice of Pendency of Action: Lis Pednes
2008 Oct 2EOPResponse to Kirk's Request for Findings of Fact and Conclusions of Law
2008 Sept 25EOPResponse & Objections Concerning Motion to Settle Journal Entry
2008 Sept 24KirkProposed Journal Entry & Objection to EOP's Proposed Journal Entry & Request for Findings of Fact and Conclusions of Law
2008 Sept 19EOPProposed Journal Entry
2008 Sept 18CourtHearing Held. Parties to File Written Objections by 9/25/2008. Hearing to settle Journal Entry 10-6-2008 9:15 am. Stay to Remain in Effect
Sept 9, 2008CourtHearing Held - Court Rules in Favor of EOP/PCUSA Hearing Set for 9-18-2008 3:30pm for Bond & Settlement of Journal Entry
Aug 28, 2008CourtHearing Reset for 9-9-2008
2008 Aug 5Court Motions For Summary Judgment Are Set For Hearing On 8-28-08 AT 9:00 AM.
2008 May 19Kirk Order Granted for Kirk to file Sur-Reply by 5-19-2008
2008 May 16Kirk Unopposed Application To Grant More Time for Kirk's Sur-Reply Brief.
2008 May 7Kirk Unopposed Application To Set Hearing Of Kirk's Motion For Summary Judgment & EOP/PCUSA Counter Motions For Summary Judgment.
2008 May 5Court Order Granting Kirk Leave To File Sur-Reply To Summary Judgments By 5-16-08.
2008 Apr 24PCUSA Reply Brief In Support Of Counter Motion For Summary Judgment
2008 Apr 24EOP Reply Brief In Support Of Counter Motion For Summary Judgment
2008 Apr 17Kirk Kirk Corporation advice to the Court.
2008 Mar 3Kirk Permission for Kirk to file long reply brief.
2008 Feb 29Kirk Reply in support of Kirk's motion for summary judgment combined with respones to PCUSA'S counter montions for summary judgment (Exhibits and Compendium of Cases). - (No Person shall be deprived of Life Liberty or Property w/o Due Process of Law)
2008 Feb 7Court More Time for PCUSA? to respond to Motion to Compel
2008 Feb 5Court Kirk allowed more time to Answer PCUSA Motions for Summary Judgment and Reply to Answers to Kirk's Motion for Summary Judgment.(Served)
2008 Jan 31Court Kirk allowed until Feb 29,2008 to Answer PCUSA Motions for Summary Judgment and Reply to Answers to Kirk's Motion for Summary Judgment.
2008 Jan 30Kirk Application for Enlargement of Time to Answer Motions for Summary Judgment and Reply to Answers to Kirk's Motion for Summary Judgment.
2007 Nov 28Kirk Kirk's Reply in Support of its Motions to Compel Answers to Requests for Admissions, Interrogatories and Production of Documents from PC(USA).
2007 Nov 21Kirk Krik's Reply in Support of its Motions to Compel Answers to Interrogatories and Production of Documents from EOP.
2007 Nov 19Court Leave granted to Kirk to file Reply in Support of Kirk's Motion to Compel EOP and PCUSA Documents and Answers
2007 Nov 15EOP EOP's Response to Kirk's Motion to Compel
2007 Nov 15Court Hearing on "Kirk's Motion to Compel EOP" reset to Dec 20, 2007 at 9am(EOP objection overuled). Kirk & EOP may file briefs.
2007 Nov 9Kirk Unopposed Kirk Motion for leave to file a reply brief in support of Kirk's motion to compel answers to interrogatories and production of documents from EOP.
2007 Nov 6EOP Unopposed EOP Motion for more time to respond to Kirk's motion to compel.
2007 Oct 26Kirk Kirk's Motion to compel answers to interrogatories and production of documents from EOP and Brief in support
2007 Oct 18COURT Motion to Compel Hearing set for Nov 20, 2007 9:30am
2007 Oct 15Kirk Motion for leave to file a reply brief in support of Kirk's application for enlargement of time.
2007 Oct 9EOP EOP's response to Kirk's application for enlargement of time to answer motions for summary judgment & reply to answers to Kirk's motion for summary judgment
2007 Oct 5KIRK?? Brief of PCUSA in opposition to Kirk's motion to compel discovery
2007 Oct 5KIRK Application for enlargement of time to answer motions for Summary Judgment and Reply to Answers to Kirk's Motion for Summary Judgment.
2007 Oct 4COURT Order to extend to 10-5-2007 for PCUSA to respond to Compel Motion by Kirk
2007 Sept 19COURT Order to extend to 10-3-2007 for PCUSA to respond to Compel Motion by Kirk
2007 Sept 11COURT Grant motion to extend to 9-19-2007 for PCUSA to respond to Compel Motion by Kirk
2007 Sept 11PCUSA Unopposed motion for extension of time to respond to Compel Motion by Kirk
2007 Sept 05Kirk Kirk Supplement to Compel Motion by Kirk
2007 Aug 27Court Court Hearing on Compel Motion by Kirk 2007 Sept 20
2007 Aug 27Kirk Motion to compel PCUSA to answers to request for Admission, Interrogatories and Production of Documents.
2007 Jul 25Court Kirk Allowed until 10/22/2007 to file replys
2007 Jul 23EOP Response to Kirk's Motion for Summary Judgment
EOP's Motion for Summary Judgment and Brief
2007 Jul 19Kirk Kirk's request to file reply brief in support of MSJ
Kirk's to extend time for response to EOP MSJ
Kirk's reply briefs to EOP response to Kirk's MSJ.
2007 Jul 13PCUSA Application For Brief in Opposition to Kirk's Summary Judgment.
2007 Jul 7EOP Motion For Summary Judgment and brief.
2007 Jun 26Court EOP granted to 7-13-07 To File Response To Kirk's Motion For Summary Judgment.
2007 Jun 18Kirk Kirk's reply to EOP's Counterclaims
2007 Jun 12Court PCUSA? granted to 7-13 to respond to Kirk's Motion for Summary Judgment
2007 Jun 08Court Time Extended (6/18) to Kirk to file Response to Counterclaims
2007 May 29 EOP EOP's Counterclaims
2007 May 24Court Leave granted to file Counterclaims.
2007 May 23EOP Motion for leave to file Counterclaims with List of Authorities.
2007 May 1Court Agreed Protective Order signed by Judge
2007 Apr 12Court EOP's Motion to compel is granted in part and denied in part.
2007 Apr 09Kirk Response To EOP's Motion To Compel Answers To Interrogatories & Production Of Documents & Brief In Support
2007 Apr 02Court Motion To Compel Is Set For Hearing On 4-12-07 At 9:30 am
2007 Feb 07EOP Motion To Compel Answers To Interrogatories And Production Of Documents And Supporting Brief (A-J)
2007 Mar 03Court Order denying Stay and granting Compel.
2007 Feb 07Court Order: Granting EOP & PC(USA) time extension to respond to Summary Judgment till 2007-May-07
2007 Feb 06Court Moot: Settle Journal Entry
2007 Feb 06Court Order denying Stay and granting Compel.
2007 Jan 31EOP Motion to Settle Journal Entry
2007 Jan 22Kirk Motion for Summary Judgment and Brief
2007 Jan 22Court Grant Kirk Leave to file 15 page brief and overlong Motion
2007 Jan 10Kirk Plaintiffs reply to Counterclaims
2006 Dec 18PCUSA Answer of Defendant
2006 Nov 15EOP Answer of Defendant
2006 Nov 08Kirk Application for Scheduling Conference
2006 Oct 26Court hearing: Motion to stay DENIED, Motion to compel: GRANTED
2006 Oct 23Court hearing: under advisement
2006 Oct 19Kirk SurReply in support of Objection
2006 Oct 19Kirk Order granting Plaintiff leave to file SurReply in support of Objection
2006 Oct 18Kirk Corrected Exhibits to Objection of Stay & Produce
2006 Oct 17EOP & PC(USA) Reply to Objection of Stay & Produce
2006 Oct 10EOP Unopposed Order granting leave to file reply briefs
2006 Oct 4Kirk Plaintiff's Objection to & Motion to Strike Defendant's motion to Stay & Produce
2006 Sep 28Court Order granting Plaintiff till 2006-Oct-04 to fill response to Stay & Produce
2006 Sep 14EOP Defense Motion for Stay of Action and Brief in Support
2006 Sep 14EOP Defense Motion for order directing plaintiff to produce documents
2006 Aug 16Kirk Petition to the Court

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