Epstein Secrets

quest that Defendant’s Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowit

owing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests.” Capaz, 2007 WL 1655473 at *1. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,

s, LLC v. Goodmail Systems, Inc., 529 F.Supp. 2d 1376, 1379 (N.D. Ga. 2007); Coughlin v. Wal-Mart Stores East LP, 2008 WL 2704381 (M.D. Fla. 2008); Capaz v. Whitaker, Weinstraub & Grizzard, M.D.S, P.A., 2007 WL 1655473 (M.D. Fla. 2007). In CBT Flint Partners, the Court warned against reading the deci

fs respectfully request that Defendant's Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar

howing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at * I. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,

fs respectfully request that Defendant's Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar

howing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at * I. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,