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kezell®podhursicom Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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
kezell®podhursicom Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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
kezell®podhursicom Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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
800 Fax• 105 15R-910 Counsellor Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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
ke City, UT 84112 Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
usory and legal assertions in the Amended Complaint and the Rico Statement that attempt to track statutory language and assert bare conclusions. As Jabal and Twomblv make clear, Plaintiff cannot withstand a motion to dismiss by baldy asserting that an offense occurred and holding out hope that she "mi
kezell@podhursicom Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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
[email protected] Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P
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 Alan Dershowitz and Jabal

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSONJane Doe
PERSON
Kenneth Marra
PERSONRobert D. Critton
PERSON
Scarlett Johansson
PERSONMichael J. Pike
PERSON
Alfredo Rodriguez
PERSON
Oliver Stone
PERSON
Sarah Kellen
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONKatherine W. Ezell
PERSONRobert C. Josefsberg
PERSON
United States District Court
ORGANIZATION
Supreme Court
ORGANIZATION