In the recent case of Dillworth v. Diaz, et al., the Bankruptcy Court of the Southern District of Florida dealt with the question of whether the heightened pleading standard set forth by the U.S. Supreme Court in Bell Atlantic Corp. v. Twombly and Ashcrof v. Iqbal apply to affirmative defenses. The Court in this case held that such heightened pleading standard does not apply to affirmative defenses.