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e incor- rect.’’’) (internal citations omitted). The Court bears in mind that it is bound by Sec- ond Circuit precedent while Judge Robertson applied D.C. Circuit law. Menowitz v. Brown, 991 F.2d 36, 40-41 (2d Cir.1993) (explaining transferee court is to apply its interpretation of federal law, not that of the
Page: HOUSE_OVERSIGHT_017846 →e war with the United States). 26. Plaintiffs argue that Judge Robertson held them to an unnecessarily stringent theory of causation and submit that the D.C. Circuit’s subsequent decision in Kilburn v. Socialist People’s Libyan Arab Jamahiriya, 376 F.3d 1123 (D.C.Cir.2004), effectively overrules the holding in Burne
Page: HOUSE_OVERSIGHT_017862 →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
Page: HOUSE_OVERSIGHT_017886 →Qaeda organization” because of its support of an al Qaeda guest house in Egypt, its office’s close proximity to Osama bin Laden’s personal office in Sudan, and its relationship with bin Laden’s brother-in-law Defendant Mohammed Jamal Khalifa. (Ashton Compl. F§ 310, 315, 317; Burnett Compl. Ff 234, 239,
Page: HOUSE_OVERSIGHT_017924 →is is another name for the Muslim World League. 5 Plaintiffs bring the Court’s attention to Mwani v. bin Laden, 417 F.3d 1 (D.C.Cir.2005), in which the D.C. Circuit found that Osama bin Laden and al Qaeda were subject to personal jurisdiction under Rule 4(k)(2) because they had “engaged in unabashedly malignant a
Page: HOUSE_OVERSIGHT_017933 →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
Page: HOUSE_OVERSIGHT_023377 →fendants’ provision of material support to al-Qaeda was knowing or, at the very least, reckless. The reasonableness of this inference is supported by the D.C. Circuit’s judicial review of habeas petitions brought on behalf of Guantanamo Bay detainees. See, e.g., Al Alwi v. Obama, 653 F.3d 11 (D.C. Cir. 2011); Uthman
Page: HOUSE_OVERSIGHT_023396 →Entities connected to both Sudan and the D.C. Circuit

Jeffrey Epstein
PERSON
United States
LOCATION
Donald Trump
PERSON
Barack Obama
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Joe Biden
PERSON
Yemen
LOCATION
Bloomberg L.P.
ORGANIZATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSONEmmy Taylor
PERSON
Lebanon
LOCATION
Michael Jackson
PERSON
Marc Rich
PERSON
Michael Cohen
PERSON
George Mitchell
PERSON