Epstein Secrets

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

84 Defendant's MOTION for Extension of Time to File Response as to 23. MOTION for Protective Order Against Piecemeal Depositions of Jane Doe No. 4, Motion to Consolidate Cases for Purposes ofDiscovery, and Incorporated Memorandum of Law, by Jeffrey Epstein. (Pike, Michael) Modified on 4/20/2009 (Is). (Entered: 04/16/2009)

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

2009 (Is). (Entered: 04/16/2009) 04/17/2009 w RESPONSE to Motion re 58 MOTION for Protective Order Against Piecemeal Depositions ofJane doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support filed by Jeffrey Epstein. Replies due by 4/27/2009. (Attachments: # 1 Exhi

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

for Extension of Time to Respond re (66 in 9:08-cv-80119-ICAM) MOTION for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support in case 9:08-cv-80380-KAM; granting (31) Motion for Extension of Time to