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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). Defe

'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 No. 376980) ahorowitz@ herman

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

ot 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 No. 376980) ahorowitz@ herman

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

ot 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 No. 376980) ahorowitz@ herman

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

trial in this action on all claims so triable. Dated: February 27, 2009 Respectfully submitted, By: s/ Adam D. 1 lorowitz Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (FL Bar No. 376980) MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florid

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

y trial in this action on all claims so triable. Dated: February 27, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (FL Bar No. 376980) MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florid

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

o triable. Dated: February 27, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 94724≤) Adam D. Horowitz (FL Bar No. 376980) MERMELSTEIN & HOROWITZ, P.A. Attorneysfor Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: Fax: - 6 - EFTA0017586

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

y trial in this action on all claims so triable. Dated: February 27, 2008 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssmasexabuseattomev.com 6980) MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami- 60 Tel: F