Epstein Secrets

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, 544 U.S. 336, 346 (2005). This is a liberal pleading requirement, one that does

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

right of EFTA00234845 Case 9:08-cv-80893-KAM Document 87 Entered on FLSD Docket 06/12/2009 Page 2 of 26 Doe v. Epstein Page No. 2 action,'" Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007), and just recently made clear that "Twombly expounded the pleading standard for "'all civil actions'" and not j

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

laintiff'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, 544 U.S. 336, 346 (2005). This is a liberal pleading requirement, one that does

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

laintiff'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, 544 U.S. 336, 346 (2005). This is a liberal pleading requirement, one that does

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