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for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
o 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 legal unit, or a
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
o 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 legal unit, or a
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
o 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 legal unit, or a
Entities connected to both Counts and I. Tompkins

Jeffrey Epstein
PERSONJane Doe
PERSON
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSON
Kenneth Marra
PERSONMichael J. Pike
PERSON
Alan Dershowitz
PERSONErie R.Co
ORGANIZATIONRobert D. Critton
PERSONJack Goldberger
PERSON
United States
LOCATIONAtterbury Goldberger & Weiss
ORGANIZATIONTwombly
PERSON
Rhodes
PERSONFL Bar No.
ORGANIZATIONthe State of New York
LOCATIONAmerican Bd
ORGANIZATION
Lewis Tein
PERSON
Bradley Edwards
PERSONHerman & Mermelstein, P.A.
ORGANIZATION