Ruiz-Morales v. American Airlines, Inc.

MOTION Submitting AMENDED MOTION TO STRIKE PARAGRAPHS 6 TO 39 OF AMERICAN AIRLINES STATEMENT OF UNCONTESTED FACTS

D.P.R.March 19, 2019

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO ROXANNE RUIZ MORALES Plaintiff v. AMERICAN AIRLINES, INC., Defendant CIVIL NO. 16-2837 (ADC) Re: Wrongful Termination PLAINTIFF ROXANNE RUIZ’MOTION SUBMITTING AMENDED MOTION TO STRIKE PARAGRAPHS 6 TO 39 OF AMERICAN AIRLINES STATEMENT OF UNCONTESTED FACTS (DOCKET #28) DUE TO INADVERTENT FILING OF A DRAFT TO THE HONORABLE COURT: NOW COMES THE PLAINTIFF, Roxanne Ruiz, and respectfully presents an “Amended Motion to Strike Paragraphs 6 to 39 of American Airlines Statement of Uncontested Facts (Docket #28)” and respectfully asks the court to consider the Amended Motion submitted herewith instead of the Motion to Strike filed last night at Docket #35. This morning, plaintiff realized that it had inadvertently submitted a draft of the Motion to Strike and it had failed to submit the exhibits in support thereof. This occurred as a result of the undersigned working until late hours to meet the deadline to oppose the dispositive motion filed by AA which was also filed last night. This amendment will not cause any harm to the parties or the court, since the Motion to Strike (Docket #35) was filed less than 24 hours ago. In any event, the undersigned apologizes for any inconvenience this make cause and respectfully requests that the court consider the Amended Case 3:16-cv-02837-ADC Document 38 Filed 03/19/19 Page 1 of 2 Motion to Strike submitted herewith instead of Docket #35. This is to certify that this motion is being filed through the ECF filing system, which will automatically notify all counsel of record. Respectfully Submitted in San Juan, Puerto Rico, this 19 day of March 2019.th Berkan/Mendez Calle O’Neill G-11 San Juan, Puerto Rico 00918-2301 Tel.: (787) 764-0814 Fax.: (787)250-0986 berkanmendez@gmail.com By:/s/ Mary Jo Mendez Mary Jo Mendez US DC No. No.209407 mendezmaryjo@microjuris.com Case 3:16-cv-02837-ADC Document 38 Filed 03/19/19 Page 2 of 2