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

exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language

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

exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language

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

exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language

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

exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language

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

exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language

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

l exploitation of children) ... [to] sue therefor." Smith 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language