In spite of the Second District Appellate Court decision in Sacksteder v. Senny, 2012 Ohio 4452 (2012), which declined to adopt the more stringent pleading standards set out by the U.S. Supreme Court in Bell Atlantic v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. 662 (2009), it is still possible to get inadequately pled complaints dismissed via a motion to dismiss or for judgment on the pleadings. Coolidge Wall recently succeeded in having an intentional infliction of emotional distress count dismissed in a discrimination suit because the plaintiff had not pled facts sufficient to demonstrate the …