Epstein Secrets

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

bjectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009). -6- EFTA00212898 Case 9:09-cv-80591-KAM Do

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

bjectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009). -6- EFTA00212965 Case 9:09-cv-80591-KAM Do

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

bjectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009). -6- EFTA00221368 Case 9:09-cv-80591-KAM Do

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

bjectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009). -6- EFTA00221465 Case 9:09-cv-80591-KAM Do

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

bjectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009). -6- EFTA00189754 Case 9:09-cv-80591-KAM Do

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

jectively describe(] the measure's ... effect upon ... current law" so that Congress can make infonned judgments about the impact of proposed bills. See The Library of Congress, About CM Summary, available at http://thomaaloc.govrbss/abt_dget.btml (last visited May 10, 2009). -6- Case No. 08-80736-CV-MARRA P-011847 EFTA0