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state a claim upon which relief can be wanted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co.l. 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
ein Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 Fax: 442-6744 Email: ATTORNEY TO BE NOTICED Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: Email: ATTORNEY TO BE NOTICED https://ect flsd.uscourts.gov/cgi-bin/DktRpt.
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.l. 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
Database - flsd Page 2 of 15 ATTORNEY TO BE NOTICED Defendant Jeffrey Epstein Amicua United States of America represented by Michael James Pike Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: 515-3148 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert Deweese Critto
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. v. 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
5 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman https://ecf.flsd.useourts.gov/egi-bin/DIctRpt.p17825839498761356-L_801_0-1 6/10/2009 EFTA00175220 CM/ECF - Live Database - flsd Page 2 of 7 51
Entities connected to both Tompkins and Burman Critton Luttier & Coleman

Jeffrey Epstein
PERSONRobert D. Critton
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONJane Doe
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Wilbur Ross
PERSON
Scarlett Johansson
PERSONMichael J. Pike
PERSON
Kenneth Marra
PERSON
Lewis Tein
PERSONCoconut Grove
LOCATION
United States
LOCATION
George W. Bush
PERSONMermelstein
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON
Adam D. Horowitz
PERSON
Julie K. Brown
PERSONStuart S. Mermelstein
PERSON