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elief, and the statement must "give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests." Swierkiewicz v. Sorema N.A. 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8)• see also Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 545 (2007); Dura Phann., Inc. v. Broudo,
rida Statute 796.09. Defendant seeks dismissal of Counts II and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as
elief, and the statement must "give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests." Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8); see also Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955, 1964 (2007); Dura Pharm., Inc. v. Bro
et 12/10/2009 Page 6 of 9 provide Defendant with sufficient notice of the underlying factual bases for the claims raised in the thirty-one counts. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as
lief, and the statement must "give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8); see also Bell Atlantic Corp. v. Twomblv, 550 U.S. 544, 545 (2007); Dura Pharm., Inc. v. Broudo
orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as
lief, and the statement must "give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8); see also Bell Atlantic Corp. v. Twomblv, 550 U.S. 544, 545 (2007); Dura Pharm., Inc. v. Broudo
orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as
Entities connected to both Sorema N.A. and Standard of Review

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSONChoice, Inc.
ORGANIZATIONChambers
PERSONBell Atlantic Corp.
ORGANIZATIONTwombly
PERSON
Erickson
PERSON
United States
LOCATIONPardus
PERSONFLSD Docket
ORGANIZATIONDura Pharm.
ORGANIZATION
Swierkiewicz
PERSONGibson
PERSONConley
PERSONF.R.D. 608
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONPalmas Y Bambu
ORGANIZATION
Dennis
PERSONOffice of Atty
ORGANIZATION