er example, many of the questions raise issues with regard to whether to waive various privileges for doctor-patient information and records (e.g., Fla. Stat. Ann. § 456.057), and various privileges for psychotherapist-patient information and records (e.g., Fla. Stat. Ann. § 90.503) and attorney-client pr

of “rendition of legal services to the client.” Fla. Stat. Ann. § 90.502(2). Documents given by the govern

an enterprise); unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

tion. Finally, assuming arguendo that the Court were to view the dismissal of Epstein's initial claims for RICO, fraud and conspiracy and §772.101, Fla. Stat., as proving a basis for a malicious prosecution claim by Edwards, Edwards' damages for malicious prosecution must be limited to any damages arising

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 72. The breadth and scope of ROTHSTEIN, BODEN, VILLEGAS, BARNETT, FISTEN, JENNE, the Litigation Team and, potentially, L.

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 72. The breadth and scope of ROTHSTEIN, FISTEN, JENNE, the Litigation Team and, potentially, L.M.'s racketeering activity

.C. §2255(b). 1. Plaintiff's Complaint on its face does show the date that her claims accrued. II. Based on the Complaint allegations, §95.11(7), Fla. Stat., does not apply to Count I — Assault and Battery: thus, such claim is time barred. Pursuant to the allegations on the face of Plaintiff's complaint

ears later — and, thus, her claims are time barred. 7. As to Count I, Plaintiff's claim for assault and battery is time barred under §95.11(3)(o), Fla. Stat., as Plaintiff has failed to sufficiently allege "abuse" under §39.01, Fla. Stat., and thus, §95.11(7), Fla. Stat., is inapplicable. 8. As to Count

he Circuit Court for Palm Beach County, Florida under an Information to the charge of Procuring a Person Under 18 for Prostitution, in violation of Fla. Stat. & 796.03 -- would have constituted, at most, a misdemeanor if committed in New York instead of Florida. Specifically, the nearest cognate crime unde

or between May 21.2004 and June 30 2006, in the County and State Ily and feloniously engage in a scheme to defraud as defined by s. 817.034(3)(d), Fla. Stat., by engaging in a systematic, ongoing course of conduct with intent to defraud one or more persons, to wit: KARIN MODELS USA, LLC and/or JEAN LUC BR

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, E.'s racketeering activity continues to be investigated

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

uest and deposition (see Second Amended Counterclaim, ¶16) and malicious prosecution based on the filing of priors claim for violation of §772.101, Fla. Stat., Florida RICO, abuse of process, fraud and conspiracy to commit fraud (id., ¶27) -- is inherently defamatory. (To be expanded) Accordingly, Edwards

an enterprise); unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

an enterprise); unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, ■.'s racketeering activity continues to be investigated

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, racketeering activity continues to be investigated by t

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. * 64. The breadth and scope of RQWEIN, EDWARDS and, potentially, L.M.'s 4 racketeering activity continues t tigated by