Epstein Secrets

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

in Counts I and III. According to Defendant, the pleadings in this case do not satisfy "the standard of pleading" established in Bell Atlantic Corp. I. Twombly 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twomblv well beyond its intended scope. Twombly was an antitrust conspiracy cas

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

in Counts I and III. According to Defendant, the pleadings in this case do not satisfy "the standard of pleading" established in Bell Atlantic Corp. I. Twombly 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twomblv well beyond its intended scope. Twombly was an antitrust conspiracy cas

sel of record identified on the following Service List in the manner specified by CM/ECF on this 61h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermeistein, Esq. 18205 Biscayne Boulevard Suite 2218 60 Fax: ahorowitzehermanlaw.com jhermanehermanlaw.com Iriveraehermanlaw

of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp. I. Twombly 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that is plausible