169-0 Watch Tower Notice of Errata
Document Filed: October 28th, 2022
“Defendant Watch Tower Bible and Tract Society of Pennsylvania (“WTPA”) respectfully submits this Notice of Errata to correct and clarify two issues regarding WTPA’s Brief in Response to Plaintiffs’ Affidavit of Ryan Shaffer (Doc. 165) (“WTPA’s Response”).
1. WTPA’s Response incorrectly states that Plaintiffs never filed a response brief to WTPA’s Motion to Dismiss (Doc. 13) for lack of personal jurisdiction. (See Doc. 165 at 9, 23.) WTPA provides notice that it corrects that statement. Plaintiffs did file such a response brief on November 5, 20211 (Doc. 96) (although it was filed after WTPA had already withdrawn its Motion to Dismiss on November 5, 2021 (see Doc. 94)). Plaintiffs also filed a Notice Re: WTPA’s Withdrawal of its Rule 12(b)(2) Motion to Dismiss on November 5, 2021 (Doc. 95), which stated their intention to proceed with filing a response brief. (See Doc. 95 at 4, ¶ 11.)”
“2. WTPA’s Response states that Messrs. Shaffer and Murnion billed for 28 and 33 hours respectively in one 24-hour day on November 5, 2021. (See Doc. 165 at 9, 23.) While that statement correctly states the amount of hours specified for November 5, 2021, in the Declarations of Messrs. Shaffer and Murnion (see Doc. 144-2 at 13; Doc. 144-4 at 13), Plaintiffs’ counsel has since informed the undersigned that the asserted time for November 5, 2021, actually occurred over a period of unspecified time, rather than only on November 5, 2021.
DATED this 28th day of October, 2022.”
– MOULTON BELLINGHAM PC
