Epstein Secrets

howing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at * I. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,

's Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@ herman

howing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at * I. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,

's Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@ herman

howing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at * I. While the scope of Twombly may not be entirely clear, it plainly cannot be read to turn pleadings into a discovery device,

's Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@ herman