Sokolow et al v. Palestine Liberation Organization et al

Filing 51

NOTICE of Errata for docket #50 re: 50 Memorandum of Law in Support of Motion,. Document filed by Mark I. Sokolow. (Strachman, David)

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Sokolow et al v. Palestine Liberation Organization et al Doc. 51 Case 1:04-cv-00397-GBD Document 51 Filed 09/24/2007 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK MARK I. SOKOLOW, et al. Plaintiffs, v. 04-cv-00397-GBD THE PALESTINE LIBERATION ORGANIZATION, et al. Defendants. ERRATA SHEET Memorandum in Support of Plaintiffs' Motion for Summary Denial of Defendants' Motion to Dismiss for Lack of Personal Jurisdiction, or, in the Alternative, for Jurisdictional Discovery and for Related Relief In the third paragraph on page 2 of plaintiffs' Memorandum, the phrase "nd/or on the a basis of collateral estoppel" should be stricken.1 1 This phrase was inadvertently carried over from an earlier draft of the Memorandum. Because defendants' motion to dismiss for lack of personal jurisdiction is barred at the threshold under Fed.R.Civ.P. 12(h)(1), plaintiffs'instant motion to summarily deny defendants'motion is made solely on that ground. If defendants' motion is not summarily denied ­i.e. if the issue of defendants' minimum contacts is litigated in this action ­plaintiffs' reserve the right to assert that the defendants are collaterally estopped from contesting relevant factual findings and legal holdings made in Ungar. v. Palestinian Authority and in Biton v. Palestinian Interim SelfGovernment Authority. Case 1:04-cv-00397-GBD Document 51 Filed 09/24/2007 Page 2 of 2 Plaint iffs, by their Attorneys, /s/David J. Strachman David J. Strachman McInt yre, Tate, & Lynch LLP 321 South Main Street, Suite 400 Providence, RI 02903 (401) 351-7700 (401) 331-6095 (fax) Lee Squitieri Squitieri & Fearon 32 East 57th Street, 12th Floor New York, NY 10022 (212) 421-6492 (212) 421-6553 (fax) I here by certify that this pleading was sent via ECF on September 24, 2007 to the following counsel of record: Richard A. Hibey Mark J. Rochon Charles F. B. McAleer, Jr. Miller & Chevalier Chartered 655 Fifteenth Street, N.W., Suite 900 Washington, DC 20005-5701 /s/David J. Strachman 2

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