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

Case 3:08-cv-00037-H-WMC

Document 18

Filed 04/29/2008

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1 STEPHEN DANZ & ASSOCIATES STEPHEN F. DANZ SBN 68318 2 ([email protected]) MARCUS JACKSON SBN 205792 3 ([email protected]) 1550 HOTEL CIRCLE NORTH, SUITE 170 4 SAN DIEGO, CA 92108 TEL: (619) 297-9400 5 FAX: (619) 297-9444 6 Attorney for Plaintiff JAMES RICHARD STIEFEL 7 8 9 10 11 12 JAMES RICHARD STIEFEL, an individual; 13 14 v. 15 BECHTEL CORPORATION, a Corporation; BECHTEL CONSTRUCTION COMPANY, 16 a Corporation; and DOES 1 through 100, INCLUSIVE, 17 Defendants. 18 19 20 21 TO THE COURT, DEFENDANTS, AND THEIR ATTORNEYS OF RECORD: 22 23 Plaintiff JAMES RICHARD STIEFEL gives notice that, upon review of Defendants' Reply Plaintiff, CASE NO.: 08 CV 0037 H (WMc) PLAINTIFF'S NOTICE OF ERRATA REGARDING FIRST AMENDED COMPLAINT Judge: The Honorable Marilyn L. Huff Court: Courtroom 13, 5th Floor UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

24 in Support of their Demurrer and Motion to Strike the First Amended Complaint, Plaintiff's counsel 25 noticed that the First Amended Complaint, at paragraph 52, unintentionally included the allegation 26 that Plaintiff was fired as a basis for recovery within Plaintiff's cause of action for Retaliation in 27 Violation of the Americans With Disabilities Act. Plaintiff's intent was to limit this cause of action 28 1. NOTICE OF ERRATA 08 CV 0037 H (WMc)

Case 3:08-cv-00037-H-WMC

Document 18

Filed 04/29/2008

Page 2 of 2

1 to seek recovery for incidents occurring since May 2006, as stated in paragraph 51, and only rely 2 upon the fact of his termination as background factual information, as detailed in the background 3 fact section spanning paragraphs 7-31. Thus, Plaintiff consents to striking the first sentence of 4 paragraph 52 from the First Amended Complaint because the statement regarding Plaintiff's 5 termination was not intended to be alleged as a basis for Plaintiff's recovery in that, or any other 6 cause of action. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. NOTICE OF ERRATA 08 CV 0037 H (WMc) DATED: April 29, 2008 By: STEPHEN DANZ & ASSOCIATES _/s/ Marcus Jackson_______ STEPHEN F. DANZ, ESQ. MARCUS JACKSON, ESQ. Attorneys for Plaintiff JAMES RICHARD STIEFEL