EFTA00201229.pdf

Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009 Page 1 of 3 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 orneys or ain EFTA00201229 Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009 Page 2 of 3 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Notice of Filing Correction to Plaintiff's Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Complaint Page 2 of 3 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 JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 EFTA00201230 Case 9:08-cv-80811-KAM Document 59 Entered on FLSD Docket 04/14/2009 Page 3 of 3 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Notice of Filing Correction to Plaintiffs Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Complaint Page 3 of 3 COUNSEL LIST Jack A. Goldberger, Esquire West Palm Beach. FL 33401 Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. West Palm Beach. FL 33401 Robert Critton, Esquire West Palm Beach, FL 33414 Richard H. Willits, Esquire Richard H. Willits, P.A. Lake Worth, FL 33461 EFTA00201231