Epstein Secrets

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

rls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 55

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

rls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 55

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

rls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 55

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

rls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 55

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

rls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 55

Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who

ng in illicit activities with Plaintiff) or that his travel was specifically "designed to bring about such a result." Mortenson, 322 U.S. at 374. As Jabal and Twombly make clear, plaintiffs cannot withstand a motion to dismiss by baldy asserting that an offense occurred and holding out hope that they