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Michael Peter Gurdak, Michael Rol- lin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones Day (DC), Loui
0 (hereinafter "Supp. Al-Wohai- bi Aff."). a. Status of the PIF In Filler v. Hanvit Bank, a case with facts very similar to those presented here, the Second Circuit reiterated Dole Food's requirement of direct ownership for instru- mentality status. Two defendants were commercial banks majority-owned by the Ko
t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe
Michael Peter Gurdak, Michael Rol- lin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones Day (DC), Louis
Page: HOUSE_OVERSIGHT_017844 →very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts crucial to an immuni- ty determination.”)). The Second Circuit has instructed “that generally a plaintiff may be allowed limited discovery with re- spect to the jurisdictional issue; but until [plaintiff] has sho
Page: HOUSE_OVERSIGHT_017848 →bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi
ry (DC), James Ermest Gauch, Jennifer Allyson Shumaker, Jonathan Chapman Rose, Melissa Danielle Stear, Michael Peter Gurdak, Michael Rollin Shumaker, Stephen Joseph Brogan, Timothy John Finn, Jones Day (DC), Louis Richard Cohen, Wilmer, Cutler & Pickering (Washington), William Horace Jeffress, Jr., Christopher R.
Page: HOUSE_OVERSIGHT_017912 →Accordingly, the only dispute regarding SHC’s status is whether it is an organ of the Kingdom. In Filler v. Hanvit Bank, 378 F.3d 213 (2d Cir.2004), the Second Circuit considered various factors to determine whether an entity could be considered an organ of a foreign sovereign. Jd. at 217. The factors include: (1)
Page: HOUSE_OVERSIGHT_017917 →Entities connected to both Stephen Joseph and Second Circuit

Jeffrey Epstein
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United States
LOCATION
Michael Cohen
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Bradley Edwards
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Supreme Court
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George W. Bush
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New York
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Stephen Hawking
PERSONMaria Farmer
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Harvey Weinstein
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Bradley Cooper
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Alfredo Rodriguez
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United Kingdom
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Philadelphia
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Bill Clinton
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Houston
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New York City
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Barry Diller
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Prince Charles
PERSONHaley Robson
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