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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
rince Mohamed, Al Baraka In- vestment & Development Corporation and Saleh Abdullah !Camel? Abdulrahman bin Mahfouz, the Saudi Binlaclin Group, and Adel A.J. Batterjee. Finally, the last of this group of motions was entertained on 7. Abdulrahman bin Mahfouz moves to dismiss the complaint in Burnett. 8. The Saudi
d to as the “SAAR Net- work”),® Prince Turki, and Adel A.J. Bat- terjee,!’ also raised personal jurisdiction defenses. On
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 →it does not have the same connections to the United States, bin Laden, and al Qaeda that Defendants Benevolence International Foundation (“BIF”) and Adel A.J. Batterjee had. See Terrorist Attacks I, 349 F.Supp.2d at 823-25 (finding Court had personal jurisdiction over Mr. Batterjee based on his designation as a globa
Page: HOUSE_OVERSIGHT_017923 →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 Adel A.J. Batterjee
Gibson
PERSON
United States
LOCATION
Supreme Court
ORGANIZATION
Bill Clinton
PERSON
George Mitchell
PERSON
Alfredo Rodriguez
PERSON
Philadelphia
LOCATION
Houston
LOCATION
Atlanta
LOCATION
New York
LOCATION
Michael Cohen
PERSON
U.S. Treasury
ORGANIZATION
Barry Diller
PERSON
Saudi Arabia
LOCATION
New York City
LOCATION
San Diego
LOCATION
Somalia
LOCATION
Nelson
PERSON
United Kingdom
LOCATIONHaley Robson
PERSON