Epstein Secrets

ate Cases for Purposes of Discovery, and Incorporated Memorandum of Law by Jane Doe No. 4. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart) (Entered: 03/27/2009) 04/0' 009 :74 Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. Responses due by 4/20/2009 (Attachments:

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

for Purposes of Discovery, and Incorporated Memorandum of Law in Support by Jane Doe No. 3. (Attachments: # 1 Exhibit A, # 2 Exhibit BXMermelstein, Stuart) (Entered: https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p17522982239968766-L_801_0-1 6/9/2009 EFTA00175723 CM/ECF - Live Database - flsd • Pag

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

Page 5 of 14 r 435.3 KB and Incorporated Memorandum of Law in Support by Jane Doe No. 7. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart) (Entered: 03/27/2009) 03/27/2009 24 MOTION to Consolidate Cases for purposes of discovery ( Responses due by 4/13/2009), MOTION to Quash by Jan

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