Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009
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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
C. M.A.,
Plaintiff,
vs.
JEFFREY EPSTEIN and
Defendants.
| PLAINTIFF'S NOTICE OF FILING CORRECTION TO PAGE FOUR OF PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING MEMORANDUM OF LAW FILED ON APRIL 13, 2009 |
The Plaintiff, C.M.A., by and through undersigned counsel, files her Notice of Filing Correction to Page Four of Plaintiff's Memorandum in Response to Defendant, Jeffrey Epstein's, Motion to Dismiss, and states as follows:
Plaintiff's Memorandum contains a typographical error on page four. The last sentence of the quote from Hammers v. Internal Revenue Service, 988 F.2d 32 (5th Cir. 1993) on the top of page four reads "We may not look beyond them when, taken as a whole, they are rational and ambiguous," when it should read "We may not look beyond them when, taken as a whole, they are rational and unambiguous."
Respectfully submitted,
/s/Jack P. Hill
JACK SCAROLA
Florida Bar No. 169440
JACK P. HILL
Florida Bar No.: 0547808
Attorneys for Plaintiff
EFTA00201229
Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009
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C. M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Notice of Filing Correction to Plaintiff's Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Complaint
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## CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 14, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Electronic Filing generated by CM/ECF.
/s/Jack P. Hill
Florida Bar No. 169440
JACK SCAROLA
JACK P. HILL
Florida Bar No.: 0547808
Searcy Denney Scarola Barnhart & Shipley, P.A.
Attorneys for Plaintiff
EFTA00201230
Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Notice of Filing Correction to Plaintiff's Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Complaint
Page 3 of 3
## COUNSEL LIST
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
West Palm Beach, FL 33401
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
West Palm Beach, FL 33401
Robert Critton, Esquire
Burman Critton Luttier & Coleman LLP
West Palm Beach, FL 33414
Richard H. Willits, Esquire
Richard H. Willits, P.A.
Lake Worth, FL 33461
EFTA00201231