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required by Rule 8 "must simply 'give the defendant fair notice of what the plaintiffs claim is and the grounds upon which it rests' ") (quoting Conley, 355 U.S. at 47, 78 S.Ct. 99). When presented with a 12(6)(6) motion, the district court may not consider matters outside of the pleadings without
ght be, before his death Mr. Aljomaih prepared a declaration in support of his motion to dismiss. He was born in Saudi Arabia in 1915 and lived in Riyadh for most of his life. Aljomaih Decl. 113. He and his family began a company in the 1940s that now supplies automobiles, soft drinks, construction
might be, before his death Mr. Aljomaih prepared a declaration in support of his motion to dismiss. He was born in Saudi Arabia in 1915 and lived in Riyadh for most of his life. Aljomaih Decl. 13. He and his family began a company in the 1940s that now supplies automobiles, soft drinks, construction equi
Page: HOUSE_OVERSIGHT_017882 →eyond doubt, “even when the complaint is liberally con- strued, that the plaintiff can prove no set of facts which would entitle him to relief.” Id.; Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and
Page: HOUSE_OVERSIGHT_017890 →f 182, 189.) *549 2. Prince Salman’ Prince Salman is a member of the Kingdom of Saudi Arabia’s Council of Ministers, the governor of the province of Riyadh, and the President of Defendant SHC. (Prince Salman Mem. in Sup. Mot. to Dismiss at 2.) Plaintiffs allege that Prince Salman provided material suppor
Page: HOUSE_OVERSIGHT_017914 →cts and issues and to dispose of unmeritorious claims.” Swierkiewicz vy. Sorema, N.A., 534 U.S. 506, 512, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002) (citing Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957), Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit, 507 U.S. 163,
Page: HOUSE_OVERSIGHT_017925 →Entities connected to both Conley and Riyadh

Jeffrey Epstein
PERSON
Barack Obama
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Benjamin Netanyahu
PERSON
Tehran
LOCATION
Saudi Arabia
LOCATION
Lebanon
LOCATION
Donald Trump
PERSON
Yemen
LOCATION
Department of Justice
ORGANIZATION
David Rodgers
PERSON
Bloomberg L.P.
ORGANIZATION
Bahrain
LOCATION
Joe Biden
PERSON
Middle East
LOCATION
Marc Rich
PERSON
Hillary Clinton
PERSON
Jerusalem
LOCATION