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

interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos

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

interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos

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

interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos

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

interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos

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

interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos

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

e intcmet to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purpos