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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
wealthy Saudis to the Tali- ban and al Qaeda. Ashton Complaint 1259; Federal 1451. Additionally, the Federal Plaintiffs claim that, while Prince Turki was the head of DGI, Saudi Arabian intelligence officers allegedly trained a member of the al Qaecla Spanish cell in explosives and provided mater
the allegations concerning acts tak- en in his personal, as opposed to official, capacity. Id. Judge Robertson dismissed the complaint against Prince Turki for lack of subject matter jurisdiction as well. Id. Prince Sultan and Prince Turki both move to dismiss the complaints against them in Ashton v. Al
Page: HOUSE_OVERSIGHT_017845 →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 →906 F.Supp. 204, 210 (S.D.N.Y.1995) (internal quotations omitted); see also Terrorist Attacks I, 349 F.Supp.2d at 788-89 (finding Princes Sultan and Turki were foreign states for FSIA purposes to the extent Plaintiffs alleged liability for actions taken in their official capacities). 1. SHC (51 SHC co
Page: HOUSE_OVERSIGHT_017916 →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 Turki

Jeffrey Epstein
PERSONGibson
PERSON
United States
LOCATION
George W. Bush
PERSON
Supreme Court
ORGANIZATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Barack Obama
PERSON
George Mitchell
PERSON
Alfredo Rodriguez
PERSON
New York
LOCATION
Saudi Arabia
LOCATION
Michael Cohen
PERSON
Philadelphia
LOCATION
Houston
LOCATION
U.S. Treasury
ORGANIZATION
Atlanta
LOCATION
Benjamin Netanyahu
PERSON
James Baker
PERSON
Barry Diller
PERSON