Memorandum Opinion - the Circuit Court for Baltimore City

The December 22, 2006 email and the February 17, 2007 letter sent fromRothstein to StrudwickPlaintiffs argue that the December 22, 2006 email that Rothstein and RRA sent toStrudwick concerning the unfiled New York lawsuit, was the beginning of the defendants’defamatory “scheme,” 14 and therefore must be considered in determining if there is personaljurisdiction. The argument fails for two reasons. First, as a general proposition, personaljurisdiction cannot be premised solely on sending correspondence into the State. See Bond,391 Md. at 723, citing Cape, 932 F. Supp. at 128 (stating that generally, correspondence andtelephone calls with the plaintiff in the forum state are not sufficient contact with the forumstate to satisfy due process requirements). In Bond, a Maryland plaintiff filed a legalmalpractice lawsuit against his Ohio-based attorney. The plaintiff argued that Maryland hadpersonal jurisdiction over the non-resident attorney based on seven contacts over the courseof nine years in which plaintiff sought legal advice and his attorney responded either bytelephone or by letter. Id. at 731. Noting that the non-resident attorney neither solicitedbusiness in, nor maintained offices in Maryland, the Court held that the non-resident’s“contacts do not rise to the level of an ‘act by which the defendant purposefully avail[ed]himself of the privilege of conducting activities within the forum State for the purposes ofa Maryland court exercising personal jurisdiction over him . . .’” Id.Second and more importantly, while the email may be relevant evidence at trial,plaintiffs’ claims do not arise from the email sent to Strudwick, thus it is not relevant to14Plaintiffs emphasize that at the time this email was sent, contrary to the representationsmade, no lawsuit had been filed. While this point is relevant to whether the complaint states a causeof action, it is not relevant to whether Maryland has personal jurisdiction over the authors of theemail.20