1. Not Clearly Explaining the Claim 

The defendant is involved in a fraud and you provide a complicated explanation that the Court does not fully understand.   Your claim is likely to be dismissed (probably with leave to re-file once).

2. Assuming that justice will be done. 

Many frauds continue with skilled counsel, until the collapse finds limited funds and many unpaid claims.  The skilled SEC believed Madoff and not his accuser, the Wolf of Wall Street continued for years.  Do not assume that simply because a wrong has been committed that the Court will address it; you need to prove your claim clearly and convincingly at the pleading stage.

      3.  Lumping the defendants together 

No, saying the defendant willfully and deliberately conspired to defraud the plaintiff making multiple false statements resulting in the substantial losses set forth above- is not going to do it.   You will need to identify what each defendant did.  Each will pretend not to understand what it is alleged to have done wrong and a vague complaint will again be subject to dismissal

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