Epstein Secrets

s claim that would entitle him to relief." Id, (abrogating and quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

ailed." Graddick, 696 F.2d 'The parties are reminded that all documents filed conventionally (including those filed under seal) must be filed with the Clerk's Office in West Palm Beach, Florida. EFTA00222708 Case 9:08-cv-80119-KAM Document 34 Entered on FLSD Docket 08/05/2008 Page 2 of 2 796, 803 (11th Cir.

for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ay litigation o

Prior to filing this Motion, I inquired of Judge Marra's courtroom deputy whether the motion should be filed with Judge Marra. After speaking with the Clerk's Office, Judge Marra's courtroom deputy informed me that, because this related to the grand jury, the motion should be directed to the District Judge on du

s claim that would entitle him to relief." Id, (abrogating and quoting Conley I. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

."Mil I. Graddick, 696 F.2d 'The parties are reminded that all documents filed conventionally (including those filed under seal) must be filed with the Clerk's Office in West Palm Beach, Florida. EFTA00175664 Case 9:08-D, J119-KAM Docurn. a 34 Entert.... on FLSD Docket 08r,,.,i2008 Page 2 of 2 796, 803 (11t