Epstein Secrets

, 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

Counsel for Defendants Jeffrey Epstein and Sarah Kellen Bruce Reinhart, Esq. Bamhart & Bruce E. Reinhart, P.A. 33409 Co-Counsel for Plaintiff West Palm beach, FL 33401 ounse or De en Respectfully submitted, Kellen EFTA00201296 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/20

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

ON OF • CERTAIN AS9STAhrE Kass CONTACT Lww JAFFE. ADA COORDIVEDE IN TIC ACEANSMATHE awe CHIT COM PAW BEACH MOEN ECWRFICEISM 205 N EWE I'MT, RE SSA WEST PALM MACK FL MEN: TUB:HONE (561)6%.4150, WWI a ME NNE ONS Of YOUR Rear OF THE NONCE. IF YOU AM HEARING OR VOCE IMPAIRED, CALL 14304554Th. — , Form 6)1 E

, 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

33401-5012 net Counsel for Defendants Jeffrey Epstein and Bruce Reinhart, Esq. & Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm beach, FL 33401 ounse or e en an Respectfully submitted, EFTA00175324 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Pa

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

EFTA00175593 • CM/ECF - Live Database - flsd Page 6 of 21 Michael James Pike Burman Critton 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 331