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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. v. 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
& Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 retnnntif rlremict CI '2'2 133 Counsel for Defendant Jeffrey Epstein EFTA00222003 Case 9:08-cv-80119-KAM D
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. v. 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
uth Suite 1400 West Palm Beach, FL 33401-5012 561-659—8300 Fax: 835-8691 Email: [email protected] ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 EFTA00222692 Case 9:08-cv-80-OSsKA108-Eraelrleit 2Ae2of: CatliadethollIDIEIMEN07/11156138 Page 2 of 3 Coconut Grov
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
n Luther & Coleman 515 N Flagler Drive Suite 400 West Palm Beach, FL 33401-2918 Fax: 515-3148 Email: ATTORNEY TO BE NOTICED Michael Ross Tein 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
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
se 9:08-cv-8 11-KAM Document 52 Entered FLSD Docket 10, 008 Page 10 of 10 Case No. CV-80381-Marra-Johnson Page No. 10 Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Co • e, FL 33133 Fax: Counse or e endant Jeffrey Epstein teinelewistein.com Respectfully subm By: ROBERT
, 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
d Page 2 of 16 250 S. Australian Avenue Suite 1400 West Palm Beach , FL 33401 Fax: Emai LEAD ATTORNEY ATTORNEY TO BE NOTICED Guy Alan Lewis Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 Fax: 442-6744 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Jack Alan Goldberger Atterbur
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
Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm each , FL 33401-2918 Fax: 515-3148 Email: ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 Coconut e , FL 33133 Fax: 442-6744 Email: TERMINATED: 05/20/2009 ATTORNEY TO BE NOTICED Robert Deweese Critton ,
Entities connected to both Erie R.Co and Lewis Tein

Jeffrey Epstein
PERSONJack Goldberger
PERSONCoconut Grove
LOCATION
Alan Dershowitz
PERSONJane Doe
PERSONRobert D. Critton
PERSON
Kenneth Marra
PERSONMichael J. Pike
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONSouthern District
LOCATION
Jeffrey Marc Herman
PERSON
Adam D. Horowitz
PERSON
United States
LOCATIONStuart S. Mermelstein
PERSON
Scarlett Johansson
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSON
Wilbur Ross
PERSON
Bradley Edwards
PERSONLeon Black
PERSON