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

purpose). The Plaintiffs place great weight on the United States' inclusion of the "Golden Chain" in its proffer of evidence in United States v. Arnaout, the government's case against an executive of Defendant charity BIF. See Bierstein Aft at Ex. 1 (proffer). The court presiding over that case, ho

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

what purpose). The Plaintiffs place great weight on the United States’ inclusion of the “Golden Chain” in its proffer of evidence in United States v. Arnaout, the government’s case against an executive of Defendant charity BIF. See Bierstein Aff. at Ex. 1 (proffer). The court presiding over that case, howe

. Batter- jee allegedly transferred control of BIF to Defendant Enaam M. Arnaout, on Septem- ber 15, 1997.28 Burnett Complaint 1183. In October 2001, Arnaout allegedly told Batterjee he was worried about being un- der scrutiny of the U.S. government and in January 2002, Batterjee requested that Aranout rel

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

raid -- was relied upon by the Government in an Evidentiary Proffer of al-Qaeda sponsor, Enaam Arnaout, and also referenced and used as a resource in Arnaout’s sentencing hearing. See supra pp. 54-55 nn.85-86. It was cited in the 9/11 Commission’s Final Report in July 2004, see supra pp. 25-26 & n.8, and t