Epstein Secrets

required by Rule 8 "must simply 'give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests' ") (quoting Conley, 355 U.S. at 47, 78 S.Ct. 99). When presented with a 12(6)(6) motion, the district court may not consider matters outside of the pleadings without

ities through U.S. broker). In 2002, less than 2% of the securities NCB traded for its own account were issued by U.S. entities. Juco Decl. 1 15; Schenker, 2002 WL 1560788, at .3-5 (finding that a single bank account in the United States, constituting small fraction of defendant's total assets, is in

NCB Securities Inc., dissolved in Febru- ary 2001. Id. (citing Ex A of Juco Decl., the certified copy of the Certificate of Dis- solution); see also Schenker v. Assicura- zioni Generali, S.P.A, No. 98 Civ. 9186(MBM), 2002 WL 1560788, at • 4 (S.D.N.Y. July 15, 2002) (finding no per- sonal jurisdiction ov

HEEREN,CRISTINA SCARPA,JOHN F COOLEY,WILLIAM O TRUMP,IVANA WAGNER,JOE

MESSING,JOAN WENZEL CARLINO,MARY J SCHEINER,DINA O'KAIN,DEBORAH L STEPHENSON,GA

SNCB Securities Inc., dissolved in Febru- ary 2001. Jd. (citing Ex. A of Juco Decl. the certified copy of the Certificate of Dis- solution); see also Schenker v. Assicura- ziont Generali, S.P.A, No. 98 Civ. 9186(MBM), 2002 WL 1560788, at * 4 (S.D.N.Y. July 15, 2002) (finding no per- sonal jurisdiction over

securities through U.S. broker). In 2002, less than 2% of the securities NCB traded for its own account were issued by U.S. entities. Juco Decl. 915; Schenker, 2002 WL 1560788, at *3-5 (finding that a single bank account in the United States, constituting small fraction of defendant’s total assets, is insuf

eyond doubt, “even when the complaint is liberally con- strued, that the plaintiff can prove no set of facts which would entitle him to relief.” Id.; Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and