Epstein Secrets

9:08-cv-80811-KAM Document 47 Entered on FLSD Dock'e(03/12/2009 Page 4 of 21 C.M.A. v. Epstein, et al. Page 4 factual allegations"); Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote an

added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court."' Id, at 1189. See also Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009)(District Court granted plaintiff "the minimum 'actual damages' prescr

9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 4 of 21 C.M.A. v. Epstein, et al. Page 4 factual allegations"). Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote an

added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. See also Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009)(District Court granted plaintiff "the minimum 'actual damages' prescr

entitle her to relief. Conley v. Gibson, 355 U.S. 41, 45-46 (1957). The Court must accept all of plaintiffs factual allegations as true. Schuer v. Rhodes, 416 U.S. 232 (1974). Rule 8(a)(2) of the Federal Rules of Civil Procedure provides that a complaint need only be "a short and plain statement of t

violation is different. There is no language in the statute that prohibits the Plaintiff from suing for each violation, and the dicta set forth in Tilton v. Playboy Entertainment Group, Inc., 554 F. 3d 1371 (11th Cir. 2009), vaguely noting that the District Court awarded the Plaintiff "the minimum 'a