have been on notice regarding the ongoing thefts. Specifically, the amended complaint alleges that “Paul and Steven Mancuso informed FBI agents of the parking meter thefts between their guilty verdict on or about October 28, 2009 and the date set for sentencing on or about May 24, 2010.” See Dkt. No. 22 at ¶84. The amended complaint further alleges that “[t]he FBI questioned Ronald Mancuso in late November of 2009. On Wednesday, November 25, 2009, Ronald Mancuso confessed to the parking meter theft scheme.” See id. at ¶ 87. This passing reference to these events does not meet the high bar courts have set in order to recognize documents extraneous to the complaint as “incorporated by reference.” See Global Network Commc’ns, Inc. v. City of New York, 458 F.3d 150, 156 (2d Cir.2006) (<HOLDING>); Thomas v. Westchester County Health Care
holding entry of guilty plea waives challenges to the deprivation of constitutional rights that occurred prior to the entry of the guilty plea  emphasis added holding that a defendants guilty plea was unconditional where the guilty plea was not in writing and the government did not consent to it being conditional holding that a complaints reference to a guilty plea does not make the transcript of the plea proffer integral to the complaint holding that the defendants guilty plea was valid where the district court carefully questioned the defendant about whether he understood the consequences of his guilty plea recognizing that a voluntary and understanding guilty plea entered without the benefit of a plea bargain waives all nonjurisdictional defects that occurred before the entry of the plea