11.07.2015 Views

Memorandum Opinion - the Circuit Court for Baltimore City

Memorandum Opinion - the Circuit Court for Baltimore City

Memorandum Opinion - the Circuit Court for Baltimore City

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Maryland consisted of phone calls and correspondence between<strong>the</strong>m in Germany and Cape in Maryland. Defendants neverpracticed law in Maryland, never advertised or solicited businessin this State and never maintained an office here. At no timeduring <strong>the</strong> course of <strong>the</strong>ir representation of TCEC did anyDefendants or <strong>the</strong>ir agents travel to Maryland or appear in aMaryland court on behalf of Plaintiffs or undertake to per<strong>for</strong>many services in Maryland.Id. at 125-26 (emphasis added). After noting that “[b]road constructions of generaljurisdiction should be generally disfavored,” <strong>the</strong> <strong>Court</strong> held that “[t]here can be no questionon this record that general jurisdiction is lacking and <strong>the</strong> <strong>Court</strong> need pursue <strong>the</strong> issue nofur<strong>the</strong>r.” Id. at 127. The <strong>Court</strong> also went on to hold that Maryland lacked specific jurisdictionover <strong>the</strong> nonresident attorneys. Id. at 128.Here, as in Cape, RRA does not maintain an office in Maryland and none of itslawyers are licensed to practice law in <strong>the</strong> State of Maryland. Ra<strong>the</strong>r, RRA is a Florida lawfirm with principal places of business in Florida and New York. RRA’s contacts withMaryland have not been “continuous and systematic.” Maryland does not have generaljurisdiction over RRA or Rothstein.Specific JurisdictionUnlike <strong>the</strong> contacts required <strong>for</strong> general jurisdiction, contacts required <strong>for</strong> specificjurisdiction need not rise to <strong>the</strong> level of “continuous and systematic.” First American First,Inc. v. National Association of Bank Women, 802 F.2d 1511, 1516 (4 th Cir. 1986), citingHellicopteros Nacionales de Colombia v. Hall, 466 U.S. 408, 414 n. 8 (1984). In determiningwhe<strong>the</strong>r specific jurisdiction exists, <strong>the</strong> <strong>Court</strong> considers “(1) <strong>the</strong> extent to which <strong>the</strong>defendant has purposefully availed himself or herself of <strong>the</strong> privilege of conducting activitiesin <strong>the</strong> State; (2) whe<strong>the</strong>r <strong>the</strong> plaintiff’s claims arise out of those activities directed at <strong>the</strong>18

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