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

this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De

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

this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De

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

this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De

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

this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De

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

this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De