Epstein Secrets

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212905 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especiall

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212972 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especiall

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221375 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especiall

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221472 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especiall

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00189761 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especiall

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto decision, Calder'. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dail. 386,

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft'. Iqbal No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especially

et 05/06/2009 Page 9 of 29 Jane Doe II v. Epstein, et al. Page 9 1998); and generally Calder v. Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798). The United States Constitution provides that "InIci Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art.

ion that all the allegations in the complaint are true (even if doubtful in fact)." Id. The United States Supreme Court very recently made clear in Ashcroft v. lubal No. 07-1015 (U.S. May 18, EFTA00175268 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 3 of 11 Jane Doe II

cesescscsnescescsneecescsnsecescsnseeesesnseeessseseeesesnseeesnseseersnseseeeensess Arndt v. UBS AG, 342 F. Supp. 2d 132 (E.D.N.Y. 2004) .......... Ashcroft v. Iqbal, 129 8. Ct. 1937 (2009) ..eeceecseseceesseeeeeteesteeeeee Aziz v. Alcolac, Inc., 658 F.3d 388 (4th Cir. 2011) wns Balt. & Potomac R.R. v. F

nt took ‘intentional * * * tortious, actions’ and ‘knew that the brunt of th[e] injury would be felt’ in the *15 foreign forum.” Jd. at *19, (quoting Calder v. Jones, 465 U.S. 783, 789-790 (1984)). Even so, the United States argued that the questions presented by the Petition did not warrant review by the