Epstein Secrets

quest that Defendant’s Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowit

attempted to put his hands down plaintiff’s dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan v. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease).

nd, in any event, not well founded, and therefore should be denied. Dated: September 22, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman ______ . Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected]

attempted to put his hands down plaintiff’s dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan v. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see

Dismiss is moot, and, in any event, not well founded, and therefore should be denied. Dated: September 22, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar N

attempted to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan'. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see a

rue copy of the foregoing has been sent by fax and U.S. Mail to the following addressees this 26th day of January, 2009: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 a horowitz(&hermanlaw.com

the Fifth Amendment's "basic functions ... is to protect innocent men ... `who otherwise might be ensnared by ambiguous circumstances."); Mallov v. Hogan, 84 S.Ct. 1489, 1495 (1964Xthe Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth A

nsel of record identified on the following Service List in the manner specified by CM/ECF on this sth day of October 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami. L 60 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A

asserts his Fifth Amendment privilege against self-incrimination. See DeLisi I. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy'. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth

sel of record identified on the following Service List in the manner specified by CM/ECF on this 6'" day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 60 Fax: Counsel for Plaintiff Jane Doe #3 Jack Alan Goldberger Atterbur

nt asserts his Fifth Amendment privilege against self-incrimination. See DeLisi I Bankers Ins. Company 436 So.2d 1099 (Fla. 41h DCA 1983); Malloy I Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth

sel of record identified on the following Service List in the manner specified by CM/ECF on this 61h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermeistein, Esq. 18205 Biscayne Boulevard Suite 2218 60 Fax: ahorowitzehermanlaw.com jhermanehermanlaw.com Iriveraehermanlaw

t asserts his Fifth Amendment privilege against self-incrimination. See DeLisi 1 Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy i Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-incrimination Clause applies to the states through the Due Process Clause of the Fourteenth

ff Jane Doe LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Adam D. Horowitz (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Jeffrey Marc Herman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICE

asserts his Fifth Amendment privilege against self-Incrimination. See DeLisi I Bankers Ins. Company, 436 So.2d 1099 (Fla. 41b DCA 1983)• Malloy I Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth