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The Second Circuit Court of Appeals vacated a sanctions order from the Southern District of New York that imposed a $2750 sanction on attorney Noel Hauser for submitting a revised 3(g) statement 11 weeks late. The district court based the sanctions on a letter from a law clerk setting a deadline of January 6, 1997 for the revised statement. However, the Second Circuit found that the use of the word "should" in the letter, rather than mandatory language like "shall", created ambiguity and did not unambiguous
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