Epstein Secrets

ved this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 7th day of January, 2009: Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 L m k Worth FL 33461 imo s Fax: C unse or ainti Jack Scarola, Esq. Jack P. H

by Judge William J. Zloch on 8/6/2008. (bc) (Entered: 08/06/2008) 08/07/2008 12 I 173 KB MOTION to Reassign Case TO JUDGE KENNETH MARRA by . (Willits, Richard) (Entered: 08/07/2008) 08/07/2008 B r 34.1 KB MEMORANDUM in Opposition re 6 Sealed Document, 7 Sealed Document TO MOTION TO STAY file

, 127 S.Ct. at 1965). As jurisdiction is based on diversity, it is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). On its face, Count I completely fails to allege either the necessary elements of any cause of action or the nece

ved this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 7th day of January, 2009: Richard Horace Willits, Esq. Richard H. Willits, P.A. th Lake Worth, FL 33461 Counsel for Plaintiff C.M.A. Jack Scarola, Esq. Jack P. Hill, Esq. Search Denney Scaro

, 127 S.Ct. at 1965). As jurisdiction is based on diversity, it is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. v. Tompkins 58 S.Ct. 817 (1938). On its face, Count I completely fails to allege either the necessary elements of any cause of action or the neces

RCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintiff C.M.A.. 15 THE COURT: Good morning. 16 MS. EZELL: Good morning, Your Honor. I'm Katherine 17 Ezell from Podhurs

applicable 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. S

GARCIA: Good morning, Your Honor. Sid Garcia for 11 =Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintiff _. . 15 THE COURT: Good morning. 16 MS. EZELL: Good morning, Your Honor. I'm Katherine 17 Ezell from Podhurst or

applicable 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. S

Barnhart & Shipley 2139 Palm Beach Lakes Boulevard PO Drawer 3626 , FL 33402-3626 Fax: 22/11.... Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Richard Horace Willits Richard H Willits PA 2290 10th Avenue North Suite 404 •L 33461 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Consealtintiff Jane Doe No.

s failed to 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 leg