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

d 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). Defendant

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]

d 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 also Resta

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

ed 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 also Resta

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) ,smehermanlaw.com Adam D. Horowitz (FL Bar

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

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

ed 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 I Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Resta