28
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28
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tate 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 legal unit, or a
ed claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 1550 Brickell A
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ainst tough new restrictions is growing, and some sheriffs say they won't enforce health orders." However, the New York Times (12/7, Fuller, Cowan, Tompkins, 18.61M) reports California "is averaging 21,000 new known cases a day, twice as many as the state was reporting at its worst point this summer and
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Times <https://www.nytimes.com/live/2020/11/19/world/covid- 19-coronavirus#the-cdc-strongly-urges-americans-to-avoid-travel-for-thanksgiving> (11/19, Tompkins, 18.61M) says "the new guidance...contrasted sharply with recent White House efforts to downplay the threat." Reuters <https://www.reuters.com/arti
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enforce health orders." However, the New York Times <https://www.nytimes.com/2020/12/07/us/califomia-covid-restrictions.html> (12/7, Fuller, Cowan, Tompkins, 18.61M) reports California "is avenging 21,000 new known cases a day, twice as many as the state was reporting at its worst point this summer and b
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t-toomey-says-trumps-actions-are-completely-inconsistent-with- any-kind-of-truly-democratic-society.html> (11/23, Thrush, Cochrane, Rosenberg, Fuchs, Tompkins, 18.61M) says "most congressional Republicans have refused to acknowledge Mr. Biden's victory," the AP <https://apnews.corn/article/donald-trump-ne
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ainst tough new restrictions is growing, and some sheriffs say they won't enforce health orders." However, the New York Times (12/7, Fuller, Cowan, Tompkins, 18.61M) reports California "is averaging 21,000 new known cases a day, twice as many as the state was reporting at its worst point this summer and
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since mid-December, a closely watched model from the University of Washington projects more than 589,000 dead by June 1." The New York Times (2/22, Tompkins, Bosman, Pietsch, 20.6M) reports that the US "accounts for about 20 percent of the world's known Covid deaths, but makes up just 4.25 percent of th
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/23, 3.1M) that "more Republicans are acknowledging the election is over," and while the New York Times (11/23, Thrush, Cochrane, Rosenberg, Fuchs, Tompkins, 18.61M) says "most congressional Republicans have refused to acknowledge Mr. Biden's victory," the AP (11/23, Bauder) reports that "former Waterga
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the same recommendations for everyday living,' including wearing a mask, staying six feet apart and washing your hands." The New York Times (11/19, Tompkins, 18.61M) says "the new guidance...contrasted sharply with recent White House efforts to downplay the threat." Reuters (11/19, Caspani, Borter) repo
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TUESDAY, DECEMBER 29, 2020 5:00 AM EST Federal Authorities Seek To Discover Nashville Bombing Suspect's Motive. The New York Times (12/28, McGee, Tompkins, 20.6M) says that with law enforcement officials "confident they know who set off a powerful explosion in downtown [Nashville] on Christmas morning,
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(DL) (FBI) <[email protected]>; Tilford, Timothy Coleman (NH) (FBI) <[email protected]>; To, Jane Yi Chen (SF) (FBI) <[email protected]>; Tompkins, Taylor Conrad (LR) (FBI) <[email protected]>; Toscano, Michelle Lee (NY) (FBI) <[email protected]>; TP- SQ19 <[email protected]>; TP-SQ
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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
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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
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.68 (S.D.N.Y.1989). See Klaxon Co. Ste for Electric Mfg. Co., 313 U.S. 487. 496, 6 S.Ct. 1020. 1021. 85 L.Ed. 1477 (1941): see also Erie R. Co.)! Tompkins, 304 U.S. 64. 78. 58 SO. 817, 822. LEd. 1188 (1938). Under New York's choice of law rules, when a court Is construing the meaning of a contract.
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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 necessary underlyi
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tate 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 legal unit, or a
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tate 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 legal unit, or a

Jeffrey Epstein
PersonAmerican sex offender and financier (1953–2019)

Scarlett Johansson
PersonAmerican actress (born 1984)

United States
LocationCountry located primarily in North America

Julie K. Brown
PersonAmerican journalist

Supreme Court
OrganizationHighest court of jurisdiction in the US
Michael J. Pike
PersonPerson referenced in Epstein-related documents

Virginia Giuffre
PersonAdvocate for sex trafficking victims (1983–2025)
Jane Doe
PersonPseudonym for anonymous victims/witnesses in Epstein legal proceedings

Ghislaine Maxwell
PersonBritish socialite and sex trafficker, daughter of Robert Maxwell, accomplice of Jeffrey Epstein

Stephen Hawking
PersonBritish theoretical physicist, cosmologist and author (1942–2018)

Alan Dershowitz
PersonAmerican lawyer, author, and art collector (born 1938)

Prince Charles
PersonKing of the United Kingdom and other Commonwealth realms since 2022 (born 1948)

Harry Reid
PersonAmerican politician (1939–2021)

George Mitchell
PersonFormer U.S. Senator from Maine and special envoy, connected to Epstein through flight logs and social events
Leon Black
PersonAmerican billionaire businessman (born 1951)

Rhodes
PersonAmbiguous surname reference in Epstein documents
Emmy Taylor
PersonFormer assistant to Ghislaine Maxwell, appeared in Epstein flight logs and court documents
Twombly
PersonAmbiguous - references to Cy Twombly artwork and legal citation Bell Atlantic v. Twombly in Epstein documents

Kenneth Marra
PersonAmerican judge

Michael Jackson
PersonAmerican singer, songwriter, record producer, and dancer (1958–2009)