Epstein Secrets

ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. lqbal, 129 S.Ct. 1937, 1950 2 EFTA00728575 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/03/2010 Page 3 of 10 (explaining "o

e accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp. Inc. v. Tenet Healthcare Corp. 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal sen

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. lqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need for enforcing these modest pleading requirements i

only defendant Epstein. . . ." However, the RICO enterprise must be distinct from the RICO defendant person. St. of Fla. Off. of the Atty. Gen. v. Tenet Healthcare Corp., 420 F.Supp.2d 1288, 1305 (S.D.Fla.2005) (citations omitted). "RICO forbids the imposition of liability where the enterprise is nothing more than a

ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. labal 129 S.Ct. 1937, 1950 2 EFTA_R1_00012687 EFTA01734467 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 3 of 1

accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp.. Inc. v. Tenet Healthcare Corp., 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal se

ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. labal 129 S.Ct. 1937, 1950 2 EFTA_R1_02213295 EFTA02725752 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 3 of 1

accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp.. Inc. v. Tenet Healthcare Corp., 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal se