Epstein Secrets

of Al Haramain (Bosnia, Somalia on March 11, 2002; Indonesia, Kenya, Pakistan, Tanza- nia on January 22, 2004; Afghanistan, Al- bania, Bangladesh, Ethiopia, the Nether- lands on June 2, 2004)). Thus, pursuant to Bohn, the Plaintiffs would have to al- lege specific facts showing that the Princes knew or

deter- mine which of the Network's entities have a presence in Virginia and which entities transferred money to Nada and Nasred- din. 10. Mel AJ. Batterjee The Burnett Plaintiffs claim that Defen- dant Mel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 1181. On December 21, 2004,

es of Al Haramain (Bosnia, Somalia on March 11, 2002; Indonesia, Kenya, Pakistan, Tanza- nia on January 22, 2004; Afghanistan, Al- bania, Bangladesh, Ethiopia, the Nether- lands on June 2, 2004)). Thus, pursuant to Boim, the Plaintiffs would have to al- lege specific facts showing that the Princes knew or s

Adel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 9181. On December 21, 2004, the U.S. Department of Treasury designated Mr. Batterjee as a Specially Designated Global Terrorist. See Dec. 23, 2004 Bierstein let- ter to Court; Exec. Order No. 13224. Mr. Batterjee is the chairman of Al

ization grew and expanded its global terrorist and military operations to regions as diverse *30 as the Philippines, Bosnia, Chechnya, Kosovo, Sudan, Ethiopia, Kashmir, Somalia, Palestine, Pakistan, Yemen, Kenya, Tanzania, Egypt, Indonesia, and Malaysia.! Plaintiffs’ pleadings and other record materials de

e, a close bin Laden associate who also headed al-Qaeda charity *50 fronts Benevolence International Foundation and its Saudi parent, Lajnat al Bir.* Batterjee’s primary role in al-Qaeda’s support infrastructure prompted the United States to list him as a Specially Designated Global Terrorist after the Septe