Epstein Secrets

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto v. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear

Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 6 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 3 313 3 Tel: 305 442 1101 Fax: 305 442 6744 By: Isl Michael R. Tein GUY A.LEWIS Fla

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

uth Suite 1400 West Palm Beach, FL 33401-5012 561-659—8300 Fax: 835-8691 Email: [email protected] ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 EFTA00222692 Case 9:08-cv-80-OSsKA108-Eraelrleit 2Ae2of: CatliadethollIDIEIMEN07/11156138 Page 2 of 3 Coconut Grov

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto 's. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fea

Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm each , FL 33401-2918 Fax: 515-3148 Email: ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 Coconut e , FL 33133 Fax: 442-6744 Email: TERMINATED: 05/20/2009 ATTORNEY TO BE NOTICED Robert Deweese Critton ,