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liction of a harmful or offensive contact upon the person of another''). See 3A Fla.Jur.2d Assault §1. With the standard of pleading established in Twombly, supra, in the context of the elements for assault and battery, Plaintiff has failed to state a claim upon which relief can be granted. Rule 12(b)(
ounts I and III. According to Defendant, the pleadings in this case do not satisfy “the standard of pleading” established in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twombly well beyond its intended scope. Twombly was an antitrust consp
18 U.S.C.§2422, and Defendant has not "misconstrued" the pleading standard formulated by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (11 th Cir. 2007), no
ief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atlantic Corp. v. Twombly, 127 S.Ct. at 1964-65 (citations omitted). “Factual allegations must be enough to raise a right to relief above the speculative level on the assumpt
1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely"). In discussing Twombly. the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (11 th Cir. 2007), noted - "The Supreme Court's most recent formula
Jane Doe
Person2001 album by Converge

Jeffrey Epstein
PersonAmerican sex offender and financier (1953–2019)
Gibson
PersonAmerican guitar manufacturer
Michael J. Pike
PersonJack Goldberger
PersonFamily name
Stuart S. Mermelstein
Person
Adam D. Horowitz
PersonSullivan
PersonIrish Gaelic clan

Swierkiewicz
Person
United States
LocationCountry located primarily in North America
Wright
PersonConley
PersonCensus-designated place (CDP) in DeKalb and Clayton County, Georgia, United States

Rhodes
Person
Kremer
PersonAmerican development economist
Papasan
PersonMichael R. Tein
PersonBell Atlantic Corp. V.
Organizationthe Eleventh Circuit
OrganizationSanjuan
PersonAllain
Person