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

ntent to cause such contact or the apprehension that such contact is imminent”. See Paul v. Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down pla

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]

nfliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent”); Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plai

fs respectfully request 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. Horowitz (FL Bar

he intent to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaint

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

nfliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent"); Scelta Delicatessen Support Services. Inc. 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plainti

fs respectfully request 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. Horowitz (FL Bar

he intent to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaint