At one point, the defendant was dissatisfied with the transaction agreements and sought the assistance of a lawyer from her current lawyer [Redacted]. [Redacted] also represents [Redacted] in an unrelated action [Redacted], sent in March [Redacted] a letter of credence in which she threatened to sue [Redacted] , Plaintiff and others, unless they pay $50,000,000 to the defendant. Compl. See in general. Ex.C, Letter from [Redacted] to [Redacted] et al. (Mar. 16, 2018), ECF No. 2-3 [hereafter the letter of request]. [Redacted] denied the application and counsel for the applicant sent copies of the 1992 and 1993 transaction agreements. 22-23.
Then, on Saturday, April 14, [Redacted] sent an email to [Redacted`s lawyer and lawyer for the plaintiff contains a draft complaint and threatened to file the complaint on behalf of the defendant`s "first case Monday". ID. Compl. Ex. D, e-mail from [Redacted] to [Redacted] et al. (av. 14, 2018), ECF No. 2-4; See in general. E, Draft Complaint, ECF No. 2-5.
[Redacted] sent an email to the lawyers the next day and said, "Your clients still have 12 hours to decide if they want to settle this dispute in court." Compl. Ex. F, e-mail from [Redacted] to [Redacted] et al. (av. 15, 2018), ECF No. 2-6. On the same day before the defendant could file the draft complaint on the public docket, the plaintiff filed his complaint in this motion, claiming that the defendant`s motion letter and the draft complaint contained confidential information in the 1992 and 1993 transaction agreements, and that the defendant had violated these agreements when [Redacted] sent the motion letter and the draft complaint to [Redacted] in his name. Compl. 19, 21, 25-26. The applicant also filed an emergency application for a referral ("TRO") to prevent the public filing of the draft appeal and the accompanying exhibits. See Pl. es Word.
"To face a request for dismissal" according to the Federal Civil Procedure Regulation 12 (b) (6), "an appeal must contain sufficient facts recognized as true to "claim a plausible relief on his face." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quote from Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The complaint must contain sufficient factual arguments "to obtain a right of discharge on the speculative level." Twombly, 550 U.S. to 555.
In other words, factual assertions must create a "reasonable expectation that the discovery of evidence for" will reveal the complainant`s claims. Id. at 556. The Court may also consider documents attached to a complaint, as they are part of the remedy for all purposes. GSW, Inc. v. Long Cty., 999 F.2d 1508, 1510 n.2 (11. Cir.
1993) (citing the Fed.