Epstein Secrets

e Muslim world and its Board of Directors in- cluded Haydar Mohamed bin Laden, a half-brother of Osama bin Laden. Id. 1274. • Faisal Islamic Bank Sudan was one of the five main founders of Al Shamal 815 Islamic Bank .. . . Al Shamal Islamic Bank is an instrumental bank in bin Laden's financial s

i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where

m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira

minimum contacts existed since dispute arose from a contract with substantial con- tacts with the forum) (internal quotations and citations omitted); Calder v. Jones, 465 U.S. 783, 789, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (finding personal juris- diction appropriate over non-resident de- fendants who “e

tates. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise to their clai

to work with SBG in Jeddah. Ashton Complaint 1 548; Burnett Complaint 1317. SBG allegedly continued to support Osama bin Laden after he relocated to Sudan in 1991. Ash- ton Complaint 1548; Burnett Complaint 1317. For example, SBG, through two subsidiaries allegedly supported Osama bin Laden’s participat

nt took ‘intentional * * * tortious, actions’ and ‘knew that the brunt of th[e] injury would be felt’ in the *15 foreign forum.” Jd. at *19, (quoting Calder v. Jones, 465 U.S. 783, 789-790 (1984)). Even so, the United States argued that the questions presented by the Petition did not warrant review by the

was. “Bin Ladin began delivering diatribes against the United States before he left Saudi Arabia [in 1991]. He continued to do so after he arrived in Sudan. In early 1992, the Al Qaeda leadership issued a jihad against the Western ‘occupation’ of Islamic lands...[s]pecifically singling out U.S. forces fo