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I have a pending motion to have a court clerk's error corrected. The overworked clerk accidentally filed an Answer even though a Request for an Entry of Default judgment had been submitted. The attorney for the bank did not file a timely Answer even though the judge specifically gave him a date to file by. The attorney now claims his late filed Answer was because of his inadvertence. What can I submit to the judge in my Reply that would render his claim of inadvertence null.