DECLARATION OF MARK P. WALTERS IN SUPPORT 

OF DEFENDANT’S RESPONSE TO PLAINTIFF’S 

MOTION TO STAY DISCOVERY - 1

Civil Action No. 1:15-cv-00297-JVB-SLC

JORD-6-1001P11 DEC_MPW in SUPP MSTY

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF INDIANA

FORT WAYNE DIVISION

GLOBAL ARCHERY PRODUCTS, INC., 

Plaintiff,

v.

JORDAN GWYTHER d/b/a/ LARPING.ORG 

and UPSHOT ARROWS,

Defendant.

Civil Action No. 1:15-cv-00297-JVB-SLC

DECLARATION OF MARK P. WALTERS 

IN SUPPORT OF DEFENDANT’S 

RESPONSE TO PLAINTIFF’S MOTION 

TO STAY DISCOVERY

I, Mark P. Walters, hereby state and declare as follows:

1. I am one of the attorneys representing the defendant, Jordan Gwyther, in 

the above-captioned matter. I make the following statements under penalty of perjury, in support 

of Defendant’s Response to Plaintiff’s Motion to Stay Discovery.

2. Attached as Exhibit A is a true and correct copy of Plaintiff’s First 

Interrogatories.

3. Attached as Exhibit B is a true and correct copy of Plaintiff’s First 

Requests for Production.

USDC IN/ND case 1:15-cv-00297-JVB-SLC document 46 filed 05/09/16 page 1 of 3
DECLARATION OF MARK P. WALTERS IN SUPPORT 

OF DEFENDANT’S RESPONSE TO PLAINTIFF’S 

MOTION TO STAY DISCOVERY - 2

Civil Action No. 1:15-cv-00297-JVB-SLC

JORD-6-1001P11 DEC_MPW in SUPP MSTY

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4. Mr. Gwyther responded to Plaintiff’s first interrogatories and requests for 

production within the seven (7) time-frame by producing responses and objections; documents 

produced subject to objections were produced the following day.

5. On February 26, 2016, the Court ordered the parties to brief the issues of 

personal jurisdiction and venue. That briefing was complete as of April 15, 2016.

6. Attached as Exhibit C is a true and correct copy of Mr. Gwyther’s Notice 

of Deposition for Mr. John Jackson.

7. Attached as Exhibit D is a true and correct copy of Mr. Gwyther’s initial 

disclosures.

8. Attached as Exhibit E is a true and correct copy of Plaintiff’s initial 

disclosures.

9. Mr. Jackson is an owner and principal of Plaintiff Global Archery.

10. Attached as Exhibit F is a true and correct copy of an email exchange 

between counsel for Plaintiff, Dean McConnell and me that occurred over April 1, 2016 to April 

14, 2016.

11. Attached as Exhibit G is a true and correct copy of my letter to counsel for 

Plaintiff dated May 3, 2016.

12. Attached as Exhibit H is a true and correct copy of an email from counsel 

for Plaintiff to me dated May 3, 2016.

DATED: May 9, 2016

s/Mark P. Walters

Mark P. Walters at Seattle, King County, WA

USDC IN/ND case 1:15-cv-00297-JVB-SLC document 46 filed 05/09/16 page 2 of 3
DECLARATION OF MARK P. WALTERS IN SUPPORT 

OF DEFENDANT’S RESPONSE TO PLAINTIFF’S 

MOTION TO STAY DISCOVERY - 3

Civil Action No. 1:15-cv-00297-JVB-SLC

JORD-6-1001P11 DEC_MPW in SUPP MSTY

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CERTIFICATE OF SERVICE

I hereby certify that on May 9, 2016, I electronically served the foregoing with this 

CERTIFICATE OF SERVICE upon the following attorney of record: 

Dean E. McConnell 

9795 Crosspoint Blvd., Suite 185

Indianapolis, IN 46256 

dean@dean-mcconnell.com

Attorney for Global Archery Products, Inc.

Gregg S. Gordon

ggordon@geistlaw.com

James P. Fenton

803 South Calhoun Streen, 4th Floor

Fort Wayne, IN 46802

fenton@eflawyers.com

Attorney for Amicus Curiae Electronic Frontier Foundation

LOWE GRAHAM JONESPLLC

s/Laurie Gero

Laurie Gero

USDC IN/ND case 1:15-cv-00297-JVB-SLC document 46 filed 05/09/16 page 3 of 3