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allege that Rabita Trust is a charitable organization which was created to organize the repatriation and rehabilitation of stranded Pakistanis from Bangladesh. Founded in 1988, the trust fund was started jointly by the government of Pakistan and the Saudi-based charity, [Defendant MWL]. Rabita Trust receive
Page: HOUSE_OVERSIGHT_017922 →ownership of shares m Texas corporations, on its own, cannot be considered sufficiently systematic and continuous to establish general jurisdiction. Helicopteros, 466 U.S. at 414-16, 104 S.Ct. 1868 (finding CEO’s travel to forum for contract negotiations, employees’ travel to forum for training, receipt of fun
Page: HOUSE_OVERSIGHT_017922 →and branches of Al Haramain (Bosnia, Somalia on March 11, 2002; Indonesia, Kenya, Pakistan, Tanza- nia on January 22, 2004; Afghanistan, Al- bania, Bangladesh, Ethiopia, the Nether- lands on June 2, 2004)). Thus, pursuant to Bohn, the Plaintiffs would have to al- lege specific facts showing that the Princ
liat- ed. These contacts are not sufficiently "systematic and continuous" to maintain general jurisdiction over a defendant in this action.8' See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in foru
) and branches of Al Haramain (Bosnia, Somalia on March 11, 2002; Indonesia, Kenya, Pakistan, Tanza- nia on January 22, 2004; Afghanistan, Al- bania, Bangladesh, Ethiopia, the Nether- lands on June 2, 2004)). Thus, pursuant to Boim, the Plaintiffs would have to al- lege specific facts showing that the Princes
Page: HOUSE_OVERSIGHT_017866 →affiliat- ed. These contacts are not sufficiently “systematic and continuous” to maintain general jurisdiction over a defendant in this action.** See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in forum
Page: HOUSE_OVERSIGHT_017881 →Entities connected to both Bangladesh and Helicopteros

George W. Bush
PERSON
United States
LOCATION
Bill Clinton
PERSON
John F. Kennedy
PERSON
New York
LOCATION
Prince Charles
PERSON
Stephen Hawking
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Houston
LOCATION
Yemen
LOCATION
Philadelphia
LOCATION
Lawrence Krauss
PERSON
Michael Cohen
PERSON
Ethiopia
LOCATION
Alfredo Rodriguez
PERSON
Malaysia
LOCATION
Lebanon
LOCATION
United Kingdom
LOCATION
Kuwait
LOCATION