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, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0021
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
, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0021
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
, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0022
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
, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0022
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
, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0018
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
is 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson'. Alloyd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[] to the normal rule ... that "identical words used in different parts of -27- Case No.
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
Entities connected to both Gustafson and Jabal

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Jeffrey Epstein
PERSONJane Doe
PERSONLeon Black
PERSONTwombly
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PERSONAhsan Iqbal
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Prince Andrew
PERSONEvans
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George W. Bush
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Mortensen
PERSONJack Goldberger
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Griffith
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONMichael J. Pike
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Corley
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Green
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United States District Court
ORGANIZATIONEllis
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