Free Notice (Other) - District Court of Colorado - Colorado

Case 1:00-cv-02555-JLK-BNB

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Filed 06/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action Number: 00-cv-2555-JLK-BNB PAMELA CLIFTON, Plaintiff, v. NURSE IONA EUBANK, in her individual capacity; OFFICER ANAYA, in her individual capacity; OFFICER WILKS, in her individual capacity, Defendants. NOTICE OF ERRATA re: PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT Plaintiff, Pamela Clifton, by and through counsel, David A. Lane, Mari Newman, and Marcel Krzystek of KILLMER, LANE & NEWMAN, LLP, hereby file the following Notice of Errata in order to correct the following: 1. On June 19, 2006, Plaintiff filed her Response to Defendants' motion for

summary judgment. Since that filing, counsel has been made aware of errors in the brief involving the transposition of two of the Defendants' names. 2. Plaintiff's Statement of Additional Disputed Fact number 2 (page 5) attributes the

statement that there were "plenty of women down there that know how to birth babies" to Defendant Anaya. That statement was made by Defendant Wilks. (Exhibit 1, Clifton Depo., 17:4 ­ 7)

Case 1:00-cv-02555-JLK-BNB

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3.

Conversely, the statements that it was "county time" and that Ms. Clifton could

"go to the bathroom" in Statement of Additional Disputed Fact number 7 (page 6) were made by Defendant Anaya, not Defendant Wilks. (Exhibit 1, Clifton Depo., 17:23 ­ 19:7) 4. The statements are accurately attributed between Defendants Anaya and Wilks in

the argument section of the brief. 5. Undersigned counsel apologizes for any confusion caused by such errors.

Respectfully submitted this 20th day of June, 2006. KILLMER, LANE & NEWMAN, LLP s/ Marcel Krzystek ____________________________ David A. Lane Mari Newman Marcel Krzystek The Odd Fellows Hall 1543 Champa Street, Suite 400 Denver, Colorado 80202 (303) 571-1000 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that on June 20th, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses:
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Thomas J. Lyons [email protected]; [email protected];[email protected] Edmund Martin Kennedy [email protected] [email protected];[email protected]

and I hereby certify that I have mailed or served the document or paper to the following participants in the manner (mail, hand-delivery, etc.) indicated by the non-participant's name: Vincent M. Garvey U.S. Department of Justice Civil Division, Federal Programs Branch 2

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901 E Street, N.W., #946 Washington, DC 20530 Pamela Clifton 1550 S York St. Denver, CO 80210-2817 s/ Marcel Krzystek ________________________________

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