'Twombly' article very helpful

This letter was sent to Andrée S. Blumstein, who wrote the referenced article.

Thank you again! Your article in the July Tennessee Bar Journal, "Twombly Gets IQBAL-ED" was another excellent example of your helpful analysis in this evolving procedural issue. It is of great interest to those of us who still call ourselves "trial lawyers."

I must confess that the constantly changing nuances surrounding the determination of Rule 12 Motions to Dismiss make it virtually impossilby for me to stay current. Fortunately, we have your thoughtful article to guide us on this elusive subject.

— Joe E. Manuel, Chattanooga


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