a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678, 129 S.Ct. 1937 (quoting Twombly, 550 U.S. at 570, 127 S.Ct. 1955). “[T]he pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. (quoting Twombly, 550 U.S. at 555, 127 S.Ct. 1955). District courts within the Fifth Circuit have divided as to whether Woodfield’s fair-notice standard continues to apply to pleading affirmative defenses and counterclaims, or whether Twombly and Iqbal’s plausibility standard applies. Compare, e.g., Vargas v. HWC Gen. Maintenance, LLC, 2012 WL 948892, at *2 (S.D.Tex. Mar. 20, 2012) (<HOLDING>); with Floridia v. DLT 3 Girls, Inc., 2012 WL
holding that the pleading standard set forth in twombly applies to all civil actions holding that where a complaint pleads facts that are merely consistent with a defendants liability it stops short of the line between possibility and plausibility of entitlement to relief  holding that twombly and iqbals plausibility standard applies holding that the preponderance of the evidence standard applies to  523 claims recognizing the circuit split and applying the subjective standard as more stringent without deciding which standard applies