Epstein Secrets

10/06/2008 52 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 53 Unopposed MOTION for Extension of Time to File Response as to 52 Defendant's MOTION to Dismiss 42 Am

09 Page 8 of 8 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Golc s i lber er Esq. Robert D. Critton. Es /s/ Adam D. Horowitz - 8 - EFTA00175866 Case 9:08-cv-8 11-KAM Document 71 Entered FLSD Docket 04 009 Page 1 of 7 UNITED STATES DISTRI

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

10/06/2008 46 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 4/ Unopposed MOTION for Extension of Time to File Response as to 46 Defendant's MOTION to Dismiss 42 Am

Fax. 6 EFTA00175615 Case 9:08-cv-80( •KAM Document 40 Entered d LSD Docket Ofd '2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Attorneys for Defendant Jetty Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

2/2009 Page 20 of 20 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 22nd day of May, 2009.

e not present a federal court should hesitate to exercise jurisdiction over state claims, even though bound to apply state law to them, Erie R. Co. I. Tompkins, 304 U.S. 64.Needless decisions of state law [by a federal court] should be avoided both as a matter of comity and to promote justice between the p

10/06/2008 54 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 55 Unopposed MOTION for Extension of Time to File Response as to 54 Defendant's MOTION to Dismiss 42 Am

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

Master and let's agree to see whether, in the interim, we can resolve these Issues even before they are submitted to the S.M. Cordially yo Robe . Critton, Jr. RDC/clz cc: Jack Goldberger, Esq. L 'T•E•R•S 515 N. PLACILER DRIVE SUITE 400 / WEST PALM BEACH, FLORIDA 33401 TELEPHONE (561) 842-2820 F

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3

Master and let's agree to see whether, in the interim, we can resolve these issues even before they are submitted to the S.M. Cordially yo Robe . Critton, Jr. RDC/clz cc: Jack Goldberger, Esq. L•A'W•Y•E•R• S 515 N. FLAGLER DRIVE/SUITE 400 / WEST PALM BEACH. FLORIDA 33401 TELEPHONE (561) 842-2820

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3