Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 18 of 34 Defendant’s possession, custody, or control; is publicly available; is already in Plaintiffs’ possession, care, custody, or control; or is generally available to Plaintiffs. 6. Defendant gener...
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the Plaintiffs would show in support of this notice that Edwards
Heightened Standard In Evaluating Plaintiffs’ Pleadings 74
although the Plaintiffs were and are confident of the
plaintiffs’ allegations that defendants purposefully provided financing and other forms
of any foreign nation.” 28 U.S.C. § 1350 *136 note. The district court dismissed plaintiffs’ TVPA claims against
plaintiffs *2 were entitled to seek no relief against those who had
the facts and allegations contained in the plaintiffs’ complaints
the vast record presented by plaintiffs to the
and failed to draw inferences in the plaintiffs’ favor. The court also misconstrued the scope of
Plaintiffs lost a considerable amount of time & money. International
the press reports were erroneously connecting both Plaintiffs to
PLAINTIFFS request judgment against DEFENDANTS as follows:
Plaintiffs seeks to restore their business reputations by the payment of
courts are of course under an obligation to “assume the[] veracity” of the plaintiffs’