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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
he relocated to Sudan in 1991. Ash- ton. Complaint 1 548; Burnett Complaint 1 317. For example, SBG, through two subsidiaries allegedly supported Osama bin Laden's participation in the construc- tion of the Tahaddi road and Port Sudan Airport. Ashton Complaint 111550; 552, 553; Burnett Complaint 111319-322.
e met with members of the Taliban and representa- tives of bin Laden and agreed to not extra- dite bin Laden or close terrorist camps in exchange for bin Laden’s protection of the II, 292 F.Supp.2d at 16. This Court has re- viewed these affidavits and agrees with Judge Robertson’s assessment. For example, one
Page: HOUSE_OVERSIGHT_017850 →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 →haracterized [him] as having ‘directed organizations that have provided financial and logistical support to al-Qa-ida, [he] is the logistics chief of bin Laden’s organization and fought on bin Laden’s side in WESTLAW Afghanistan.’ ” (Ashton Compl. J¥ 304, 312, 523-24; Burnett Compl. J 236, 255, 271; Federal
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 Osama bin Laden

Barack Obama
PERSON
United States
LOCATION
Bill Clinton
PERSON
George W. Bush
PERSON
Jeffrey Epstein
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Benjamin Netanyahu
PERSON
Marc Rich
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSON
Joe Biden
PERSON
Julie K. Brown
PERSON
Tehran
LOCATION
Hillary Clinton
PERSON
Stephen Hawking
PERSON
al-Qaeda
ORGANIZATIONLeon Black
PERSON
Middle East
LOCATION
Yemen
LOCATION