Free Errata - District Court of California - California

Case 3:07-cv-06169-BZ

Document 13

Filed 12/31/2007

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GORDON J. ZUIDERWEG, ESQ. (SBN 83101) LAW OFFICES OF BARRY K. ROTHMAN 1901 Avenue of the Stars Suite 370 Los Angeles, California 90067 Telephone: (310) 557-0062 Facsimile: (310) 557-9080 Attorneys For Defendants Gregory S. Soter and Alan L. Rossi

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

E&M TRUST,

) ) Plaintiff, ) ) v. ) ) INTERNATIONAL HOLDING ) CORPORATION OF NEVADA, ) et al., ) ) Defendants. ) _______________________________________ )

CASE NO.:

C07-06169 BZ

NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR LACK OF SUBJECT MATTER JURISDICTION [FRCP RULE 12(b)(1)] AND FOR FAILURE TO STATE A CLAIM [FRCP RULE 12(b)(6)] OR, IN THE ALTERNATIVE, MOTION FOR MORE DEFINITE STATEMENT [FRCP RULE12(e)] Hearing: Date: Time: Place: March 19, 2008 10:00 a.m. Courtroom G, 15th Floor

TO PLAINTIFF AND ITS ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that the following errata appear in the Notice of Motion And Motion To Dismiss Complaint For Lack of Subject Matter Jurisdiction [FRCP Rule 12(b)(1)] and for Failure To State A Claim [FRCP Rule 12(b)(6)] Or, In The Alternative, Motion For More Definite Statement [FRCP Rule12(e)]; Memorandum of Points and Authorities In Support Thereof; [Proposed] Order Filed Herewith (Docket No. 10) previously served and filed on December 31, 2007, by Defendants Gregory S. Soter and Alan L. Rossi. The corrections for said errata are also set forth below. // // 1
NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS - Case No. C07-06169 BZ

Case 3:07-cv-06169-BZ

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Filed 12/31/2007

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ERRATA 1. Page 1, Lines 23-24: "located at the Ronald V. Dellums Federal Building, 1301 Clay Street, Oakland, California 94612-5217" 2. Page 4, Line 21: "`legitimate:"

CORRECTION 1. Should be: "located at 450 Golden Gate Avenue, San Francisco, California 94102"

2.

Should be:

"`legitimate'"

3.

Proof of Service, Page 10, Lines 8-15: "On December 31, 2007, I personally served the foregoing true and correct copies of the attached NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR LACK OF SUBJECT MATTER JURISDICTION [FRCP RULE 12(b)(1)] AND FOR FAILURE TO STATE A CLAIM [FRCP RULE 12(b)(6)] OR, IN THE ALTERNATIVE, MOTION FOR MORE [FRCP DEFINITE RULE12(e)];

3.

Should be: "On December 31, 2007, I deposited in the mail at Los Angeles, California, a true and correct copy of the foregoing NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR LACK OF SUBJECT MATTER

JURISDICTION [FRCP RULE 12(b)(1)] AND FOR FAILURE TO STATE A CLAIM [FRCP RULE 12(b)(6)] OR, IN THE ALTERNATIVE, MOTION FOR MORE DEFINITE STATEMENT [FRCP RULE12(e)]; POINTS MEMORANDUM AUTHORITIES OF IN

STATEMENT

MEMORANDUM OF POINTS AND A U T H O R IT IE S THEREOF; IN SUPPORT ORDER

AND

[PROPOSED]

SUPPORT THEREOF; [PROPOSED] ORDER FILED HEREWITH, in a sealed envelope, with postage prepaid, addressed to:"

FILED HEREWITH, on all parties, by placing a true and correct copy thereof in an envelope addressed as set forth below, by sealing the envelope, and by personally delivering the sealed envelope to the addressee:" 2

NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS - Case No. C07-06169 BZ

Case 3:07-cv-06169-BZ

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Filed 12/31/2007

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NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS - Case No. C07-06169 BZ

Dated: December 31, 2007

LAW OFFICES OF BARRY K. ROTHMAN

By___________________________________________ Gordon J. Zuiderweg, Esq. Attorneys For Defendants Gregory S. Soter and Alan L. Rossi

Case 3:07-cv-06169-BZ

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Filed 12/31/2007

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PROOF OF SERVICE Gordon J. Zuiderweg certifies and declares as follows: I am an attorney at law duly licensed to practice before all the courts of the State of California, and I am a member of the Law Offices of Barry K. Rothman, attorneys for Defendants Soter and Rossi herein. I am over the age of 18 and not a party to this action. My business address is 1901 Avenue of the Stars, Suite 370, Los Angeles, California 90067, which is located in the county where the mailing described below took place. On December 31, 2007, I deposited in the mail at Los Angeles, California, a true and correct copy of the foregoing NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS COMPLAINT FOR LACK OF SUBJECT MATTER JURISDICTION [FRCP RULE 12(b)(1)] AND FOR FAILURE TO STATE A CLAIM [FRCP RULE 12(b)(6)] OR, IN THE ALTERNATIVE, MOTION FOR MORE DEFINITE STATEMENT [FRCP RULE12(e)], in a sealed envelope, with postage prepaid, addressed to: E&M Trust 715 MacArthur Boulevard San Leandro, California 94577 I declare under penalty of perjury under the laws of the State of California and the laws of the United States of America that the foregoing is true and correct. Executed in Los Angeles, California on December 31, 2007.

_____________________________________________ Gordon J. Zuiderweg

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NOTICE OF ERRATA IN NOTICE OF MOTION AND MOTION TO DISMISS - Case No. C07-06169 BZ