Epstein Secrets

t Partners, the Court warned against reading the decision in Trombly too broadly: 4 EFTA00221182 Case 9:08-cv-80993-KAM Document 11 Entered on FLSD Docket 10/3112008 Page 5 of 11 In my view, Trombly did not radically alter the elementary rules of civil procedure that have governed litigation in the f

Herzfeld, 781 So.2d 1070 (F1a.2001) (noting that plaintiff alleged intentional tort of "assault and battery" based on allegations of sexual abuse); Sullivan I. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirely on an omission). A common law as

ly, Defendant's Motions are without merit and should be denied in their entirety. 2 EFTA00222006 Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/3112008 Page 3 of 11 II. Facts Plead The pleadings in these six cases are all similarly structured and assert the same claims. In the section

Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of "assault and battery" based on allegations of sexual abuse); Sullivan I. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirely on an omission). A common law as

ly, Defendant's Motions are without merit and should be denied in their entirety. 2 EFTA00222467 Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/3112008 Page 3 of 11 II. Facts Plead The pleadings in these six cases are all similarly structured and assert the same claims. In the section

Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of "assault and battery" based on allegations of sexual abuse); Sullivan I. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirely on an omission). A common law as