Free Supplement/Amendment - District Court of Colorado - Colorado

Case 1:03-cv-02355-RPM

Document 55

Filed 10/05/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 03-cv-2355-RPM LEONID DMITRUK, Administrator of the Estate of Alexander Bugaychuk, deceased, and YELENA BUGAYCHUK, an individual, and NATALIA MELNIK, an individual, and IRINA MOROZOV, personally and as administrator of the Estate of Yevgeniy Morozov, deceased, and as Guardian for SARA MOROZOV, a minor, and ELEANNA MOROZOV, a minor, Plaintiffs, v. GEORGE AND SONS' REPAIR SHOP, INC., a Colorado corporation, d.b.a. "George's Towing", GEORGE ROSLER, a resident of the State of Colorado, and JORGE LUIS LAGE, a resident of the State of Florida, and ANGEL EXPRESS, INC., a Florida corporation, Defendants. ______________________________________________________________________________ SUPPLEMENT TO PLAINTIFFS' REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT RE: NEGLIGENCE PER SE ______________________________________________________________________________

COME NOW Plaintiffs, by and through their attorney, Komron Michael Allahyari and Washington Law Group, and file their Supplement to Plaintiffs' Reply In Support of Motion for Summary Judgment re: Negligence Per Se, as follows: 1. On September 28, 2005, Plaintiffs' filed their Reply In Support of Motion for Summary Judgment re: Negligence Per Se. 2. As part of their Reply, Plaintiffs' referenced (at page 11) Exhibit 3.

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Case 1:03-cv-02355-RPM

Document 55

Filed 10/05/2005

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3.

Due to a clerical error, Exhibit 3 was inadvertently omitted as an attachment to Plaintiffs' Reply during the electronic filing process.

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Plaintiffs' respectfully supplement their Reply filed on September 28, 2005, to add Exhibit 3.

Dated this October 5, 2005. Respectfully submitted, /s_Komron Michael Allahyari____ Komron Michael Allahyari WASHINGTON LAW GROUP 1001 Fourth Avenue Plaza, 32nd Floor Seattle, WA 98154 Telephone: (206) 423-1045 Facsimile: (206) 523-0822 Email: [email protected] ATTORNEYS FOR PLAINTIFFS

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Case 1:03-cv-02355-RPM

Document 55

Filed 10/05/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on October 5, 2005, I electronically filed a true and correct copy of this document with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: Andrew Carafelli Hall & Evans, LLC 1125 17th St., Suite 600 Denver, CO 80202-2052 E-mail: [email protected]

/s_Komron Michael Allahyari____ Komron Michael Allahyari WASHINGTON LAW GROUP 1001 Fourth Avenue Plaza, 32nd Floor Seattle, WA 98154 Telephone: (206) 423-1045 Facsimile: (206) 523-0822 Email: [email protected] ATTORNEYS FOR PLAINTIFFS

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