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

aider and abettor of al Qaeda and international ter- rorist activities." Id. 11176-77. One of the hijackers on board American Airlines Flight 11, Abdulaziz al-Omari, held an account at Al Rajhi Bank Burnett Complaint 185; Rule 12(e) Statement 1143. Another hijacker, Mohammed Atta, made a transfer to this acco

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

r, aider and abettor of al Qaeda and international ter- rorist activities.” Jd. 19 76-77. One of the hijackers on board American Airlines Flight 11, Abdulaziz al-Omari, held an account at Al Rajhi Bank. Burnett Complaint 185; Rule 12(e) Statement 1 43. Another hijacker, Mohammed Atta, made a transfer to this account

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

ort included “knowingly and intentionally provid [ing] financial and bank account services” for al-Qaeda front charities and “September 11th hijacker Abdulaziz al-Omari.” JA1062-77, 1784, 2483, 3827-29.'" “Al Rajhi Bank has long known that the[se] *79 accounts ... were being used to solicit and transfer funds to terr