such as “[d]efendants have not undertaken the above practices and activities in isolation, but instead have done so as part of a common scheme and conspiracy,” D.E. Ill at ¶ 67, and “[e]aeh Defendant and member of the conspiracy, with knowledge and intent, agreed to the overall objective of the conspiracy, agreed to commit acts of fraud to relieve Class Plaintiffs of their rightful compensa tion, and actually committed such acts.” D.E. Ill, at ¶ 68. These are the kinds of “formulaic recitations” of a conspiracy claim that the Court in Twombly and Iqbal said were insufficient. See Twombly, 550 U.S. at 557, 127 S.Ct. at 1966 (noting that “a conclusory allegation of agreement at some unidentified point does not supply facts adequate to show illegality”); Iqbal, 129 S.Ct. at 1950-51 (<HOLDING>). Plaintiffs also allege that “[i]n order for
holding that the bia cannot adopt a general presumption unfavorable to applicant but instead must consider the specific facts and circumstances of each ease holding that on summary judgment a court should not adopt a version of the facts blatantly contradicted by the record holding that court of appeals may adopt such waiver rule holding that iqbals bare allegation that defendants ashcroft and mueller agreed to adopt a discriminatory policy was not entitled to the presumption of truth and should be ignored under twombly recognizing presumption