Epstein Secrets

d pursuant to Rule II, and filed by BSF, raises the specter of one set of BSF lawyers' examining another set of BSF lawyers, including name partner David Boies. Because plaintiffs are "masters of their complaints," Standard Fire Ins. Co. v. Knowles 568 U.S. 588, 595, 133 S.Ct. 1345, 185 L.Ed.2d 439 (2013

ly hoping you could come on board." a lleges that Dershowitz knew his claims of perjury were false because "Dershowitz ... knew that David Boies ("Boies"), a name partner in the Firm, met Dershowitz had in fact had sex with Plaintiff." ak at 1 with in July 2014 and agreed to represent her. 15). (

5, 167 L.Ed.2d 929 (2007)). A court must accept all well-pleaded facts as true and must draw all reasonable inferences in favor of the plaintiff. Twombly, 550 U.S. at 570, 127 S.Ct. 1955. But a court is not bound to accept as true legal conclusions that are couched as factual allegations. lqbal, 55

ugh facts "to 'state a claim to relief that is plausible on its face.' lqbal, 556 U.S. at 663, 129 S.Ct. 1937 (auoting / *570 Bell Atl. Corp. v. Twombly 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)). A court must accept all well-pleaded facts as true and must draw all reasonable infere

ord including the following: Sigrid S. McCawley Boies, Schiller & Flexner, LLP East Las Olas Boulevard

he court noted that the truth of defendant's letter was irrelevant. Instead, the letter was privileged because it amounted 5 Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007); Ashcroft v. lqbal, 556 U.S. 662 (2009). 6 Not surprisingly, Plaintiff does not cite to a single federal authority post Twombly

HON. JOHN G. KOELTL District Judge APPEARANCES BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff

not dismiss the complaint if the plaintiff has stated "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 554, 570 (2007). "A claim has SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285671 42 I877DOEC facial plausibility when the