Epstein Secrets

tion to the FSIA applies to negate the Kingdom's immunity. "[S]overeign immunity under the FSIA is immunity from suit, not just from liabili- ty." Moran a Kingdom of Saudi Arabia, 27 F.3d 169, 172 (5th Cir.1994). Because there were no factual disputes raised in the Court's resolution of this motion

i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where

m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira

ll property types. Mr. Harper previously worked for Blackstone in both New York and Los Angeles. Prior to joining Blackstone, Mr. Harper worked for Morgan Stanley's real estate private equity group in Los Angeles and San Francisco. Mr. Harper received a BS from the McIntire School of Commerce at the University

not necessarily be taken into account if Blackstone were not a public company. Legal Representation. Simpson Thacher & Bartlett LLP and Maples and Calder will act as counsel to the Partnership, the General Partner, and the Investment Advisor in connection with this offering of Interests, and represen

Deloitte & Touche I.I.P. U.S. Counsel for the Partnership and General Partner: Simpson Thacher & Bartlett LLP. Cayman Counsel for the Maples and Calder. Partnership and General Partner: ER305378-MAXWELL Blackstone Real Estate Partners Europe V 41 CONFIDENTIAL UBSTERRAMAR00001888 EFTA00237519

ception to the FSIA applies to negate the Kingdom’s immunity. “[Slovereion immunity under the FSIA is immunity from suit, not just from liabili- ty.” Moran v. Kingdom of Saudi Arabia, 27 F.3d 169, 172 th Cir.1994). Because there were no factual disputes raised in the Court’s resolution of this motion, no

minimum contacts existed since dispute arose from a contract with substantial con- tacts with the forum) (internal quotations and citations omitted); Calder v. Jones, 465 U.S. 783, 789, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (finding personal juris- diction appropriate over non-resident de- fendants who “e

tates. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise to their clai