Epstein Secrets

asis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188. -20- EFTA00212912 Ca

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

asis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188. -20- EFTA00212979 Ca

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

asis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188. -20- EFTA00221382 Ca

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

asis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188. -20- EFTA00221479 Ca

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

asis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188. -20- EFTA00189768 Ca

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

asis added). These official records are subject to judicial notice, see, e.g., Cones' I. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore'. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mant. 297 F.3d at 1188. -20- Casc No. 08-80736-

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