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Response to Motion to Dismiss

Response to Motion to Dismiss

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Published by gillespie.jude
Response to Motion to Dismiss in Kaplan University qui tam (False Claims Act) litigation.
Response to Motion to Dismiss in Kaplan University qui tam (False Claims Act) litigation.

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Published by: gillespie.jude on Oct 07, 2009
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02/01/2013

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CASE NO. 09-CV-20756-SEITZ/O=
==
=SULLIVAN
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-20756-CIV-SEITZ/O=
==
=SULLIVAN
UNITED STATES OF AMERICA,
ex rel.CARLOS URQUILLA-DIAZ,
et al.,

Plaintiffs,
v.
KAPLAN UNIVERSITY et al.,

Defendants.
______________________________________/
AGREED MOTION FOR LEAVE TO FILE CORRECTED RESPONSE
TO MOTION TO DISMISS

Relators Jude Gillespie, Carlos Urquilla-Diaz, and Ben Wilcox, by their respective attorneys, hereby respectfully file this Agreed Motion for Leave to File Corrected Response to Motion to Dismiss Second Amended Complaint. The grounds for this motion are as follows.

As ordered by the Court, Relators Gillespie, Diaz and Wilcox filed their Response to the Kaplan Defendants\u2019 Motion to Dismiss Second Amended Complaint on October 5, 2009. Due to some type of error in the PDF file conversion, the Response filed with the Court contained symbols substituted in place of apostrophes and quotation marks that had been in the original version of the Response. Undersigned counsel did not realize this technical error had occurred in the file conversion until today when a copy of the filed Response was printed. Since the inclusion of the

Case 1:09-cv-20756-PAS Document 183
Entered on FLSD Docket 10/06/2009 Page 1 of 5
CASE NO. 09-CV-20756-SEITZ/O=
==
=SULLIVAN

symbols makes the Response difficult to read, the Relators seek leave of Court to file a corrected version of the Response \u2013 a copy of which is attached hereto. Counsel for the Kaplan Defendants have been contacted and advised that they have no objection to the relief requested herein. The Relators are filling this Motion because the Clerk of the Court advised undersigned that a Notice of Striking the Response filed on October 5, 2009 would have to be submitted with the corrected Response. Undersigned counsel believes that such a notice would render the corrected Response untimely in that it would be filed one day late. Accordingly, in an abundance of caution, the Relators request leave of Court to file the corrected Response and further request that the Court deem the corrected Response timely filed.

WHEREFORE, Relators Jude Gillespie, Carlos Urquilla-Diaz, and Ben Wilcox, by their respective attorneys, hereby respectfully request that this Agreed Motion for Leave to File Corrected Response to Motion to Dismiss be granted.

Respectfully submitted,

s/ Kimberly L. Boldt
Kimberly L. Boldt, Esq.
Florida Bar No. 957399

kimberly@abbrclaw.com

Alters, Boldt, Brown, Rash & Culmo, P.A.
4141 Northeast 2nd Avenue, Suite 201
Miami, Florida 33137
Telephone (305) 571-8550

Facsimile (305) 571-8558
Case 1:09-cv-20756-PAS Document 183
Entered on FLSD Docket 10/06/2009 Page 2 of 5
CASE NO. 09-CV-20756-SEITZ/O=
==
=SULLIVAN
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-20756-CIV-SEITZ/O=
==
=SULLIVAN
UNITED STATES OF AMERICA,
ex rel.CARLOS URQUILLA-DIAZ,
et al.,

Plaintiffs,
v.
KAPLAN UNIVERSITY et al,

Defendants.
__________________________________/
CERTIFICATE OF SERVICE

I hereby certify that on_____________, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.

s/ Kimberly L. Boldt
Kimberly L. Boldt, Esq.
Florida Bar No. 957399
kim@abbrclaw.com
Case 1:09-cv-20756-PAS Document 183
Entered on FLSD Docket 10/06/2009 Page 3 of 5

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