HomeMy WebLinkAbout2018CV217 - MONTGOMERY V. CHERNAK, HOWARD & BROUGH - 030 - DEFENDANTS' NOTICE OF CORRECTION TO CITATION WITHIN REPLY IN SUPPORT OF MOTION TO DISMISS3060192.1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 18-cv-00217-REB-KLM
WILLIAM MONTGOMERY,
Plaintiff,
v.
MATTHEW CHERNAK,
MIKE HOWARD, and
MATTHEW BROUGH,
Defendants.
_____________________________________________________________________
DEFENDANTS’ NOTICE OF CORRECTION TO CITATION WITHIN
REPLY IN SUPPORT OF MOTION TO DISMISS
______________________________________________________________________
Defendants Matthew Chernak, Mike Howard and Matthew Brough, by and through
their counsel, Thomas J. Lyons, Esq., and Christina S. Gunn, Esq., of Hall & Evans,
L.L.C., hereby respectfully submit this Notice of Correction to Citation within Reply in
Support of Motion to Dismiss Plaintiff’s Amended Complaint, as follows:
1. On June 20, 2018, Defendants filed their Reply in Support of Motion to
Dismiss Plaintiff’s Amended Complaint (“MTD Reply brief”). [ECF 28.]
2. Upon further review, Defendants determined a case citation within the MTD
Reply brief erroneously misidentified the Court which authored the opinion. This error was
an inadvertent mistake.
Case 1:18-cv-00217-REB-KLM Document 30 Filed 06/26/18 USDC Colorado Page 1 of 3
2
3060192.1
3. Specifically, page 3 of the MTD Reply brief states that the Martin case was
decided by the Tenth Circuit, but the case was actually decided by the United States
District Court for the Western District of Oklahoma. The proper citation follows:
Martin v. City of Okla. City, 180 F. Supp. 3d 978, 989 (W.D. Okla. 2016).
4. Counsel for the Plaintiff is aware of the citation change and that Defendants
would be filing this Notice of Correction.
Dated this 26th day of June, 2018.
Respectfully submitted,
s/ Christina S. Gunn _____
Thomas J. Lyons, Esq.
Christina S. Gunn, Esq.
Hall & Evans, L.L.C.
1001 17th
Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
lyonst@hallevans.com
gunnc@hallevans.com
ATTORNEYS FOR DEFENDANTS CHERNAK,
HOWARD, AND BROUGH
Case 1:18-cv-00217-REB-KLM Document 30 Filed 06/26/18 USDC Colorado Page 2 of 3
3
3060192.1
CERTIFICATE OF SERVICE (CM/ECF)
I HEREBY CERTIFY that on the 26th day of June, 2018, 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 e-mail addresses:
Raymond K. Bryant
raymond@rightslitigation.com
s/ Nicole Marion, Legal Assistant to
Christina S. Gunn, Esq. of
Hall & Evans, L.L.C.
Case 1:18-cv-00217-REB-KLM Document 30 Filed 06/26/18 USDC Colorado Page 3 of 3