Asia Economic Institute et al v. Xcentric Ventures LLC et al

Filing 143

NOTICE filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. Notice of Errata Re DN-141, DN-142 (Attachments: # 1 Exhibit A to Notice of Errata (Corrected Opposition to Defendants' Rule 11 Motion [DN-135]))(Borodkin, Lisa)

Asia Economic Institute et al v. Xcentric Ventures LLC et al

Doc. 143

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

DANIEL F. BLACKERT, ESQ., CSB No. 255021 LISA J. BORODKIN, ESQ. CSB No. 196412 Asia Economic Institute 11766 Wilshire Blvd., Suite 260 Los Angeles, CA 90025 Telephone [phone] Facsimile [phone] [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiffs, Asia Economic Institute LLC, Raymond Mobrez, and Iliana Llaneras UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) Case No.: 2:10-cv-01360-SVW-PJW ) ) The Honorable Stephen V. Wilson ) ) PLAINTIFFS' NOTICE OF ) ERRATA REGARDING Plaintiffs, ) PLAINTIFFS' OPPOSITION TO ) DEFENDANTS' MOTION FOR vs. ) SANCTIONS PURSUANT TO ) FEDERAL RULE OF CIVIL XCENTRIC VENTURES, LLC, an Arizona LLC, d/b/a as BADBUSINESS ) PROCEDURE 11 ) BUREAU and/or ) BADBUSINESSBUREAU.COM ) Hearing Date: October 4, 2010 and/or RIP OFF REPORT and/or ) Time: 1:30 PM RIPOFFREPORT.COM; BAD ) Courtroom: 6 BUSINESS BUREAU, LLC, organized )_ ) and existing under the laws of St. ) Kitts/Nevis, West Indies; EDWARD MAGEDSON an individual, and DOES ) ) 1 through 100, inclusive, ) ) Defendants. ) ) ASIA ECONOMIC INSTITUTE, a California LLC; RAYMOND MOBREZ an individual; and ILIANA LLANERAS, an individual,

NOTICE OF ERRATA RE OPP TO DEFENDANTS' MOTION FOR SANCTIONS- 0 10-cv-1360-SVW-PJW

Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Page 12 of Plaintiffs' Opposition contained a transcription error. The paragraph on page 12 should have read: "In fact, counsel did respond to the Court's question about causation, which Defendants fail to acknowledge or include in their papers. The causation was that: MS. BORODKIN: Your Honor, I apologize. This is all very recent that we discovered contradictory evidence in the record. Generally, the injury is that subjects of the Ripoff reports may have declined to pursue certain avenues of relief that may been available to them had they known the true facts which are there are limited circumstances in which reports may be taken down, but they simply don't get that far because [sic] their representations on the websites and the correspondence. Defendants stated copiously there is only one way to address these reports. See Transcript of July 12, 2010 hearing at p. 5:13-22 (emphasis added)." In addition, Plaintiffs' Opposition to Defendants' Motion for Sanctions under Federal Rule of Civil Procedure 11 did not contain a table of contents or table of authorities. A corrected copy of the Opposition correcting the transcription error and including the tables is attached hereto as Exhibit "A." Dated: September 14, 2010 Respectfully Submitted, /s/ Lisa J. Borodkin Daniel F. Blackert, Esq. Lisa J. Borodkin, Esq. Attorneys for Plaintiffs

NOTICE OF ERRATA RE OPP TO DEFENDANTS' MOTION FOR SANCTIONS- 1 10-cv-1360-SVW-PJW

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

I certify that on September 14, 2010 I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing, and for transmittal of a Notice of Electronic Filing, to the following CM/ECF registrants: David S. Gingras Gingras Law Office, PLLC 4072 E. Mountain Vista Drive Phoenix, AZ 85048 Attorney for Defendants Maria Crimi Speth Jaburg & Wilk, PC 3200 N. Central Ave. Suite 2000 Phoenix, AZ 85012 Paul S. Berra Law Offices of Paul S. Berra 1404 3rd Street Promenade Suite 205 Santa Monica, CA 90401 /s/ Lisa J. Borodkin

NOTICE OF ERRATA RE OPP TO DEFENDANTS' MOTION FOR SANCTIONS- 2 10-cv-1360-SVW-PJW