Epstein Secrets

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not j

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not j

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not j

d this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 26th day of May , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orsecic, P.A. 25 West Flagler Street, Suite 800 Fax• 105 15R-910 Counsellor Plaintiff Jack Alan Goldber

at every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not j

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not j

efsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert C. Josefsberg Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTOR

7), as the Rule 12(b)(6) pleading standard is misplaced. As discussed in Defendant's motion to dismiss, (pp. 16 - 17), the standard as detailed in Bell Atlantic Corp. V. Twomblv, 127 S.Ct. 1955 (2007), Is now the applicable standard, not Conley. Although the complaint need not provide detailed factual allegations