Epstein Secrets

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

function exception to torts exception of FSIA; (7) survivors failed to make prima fade showing necessary to establish person- al jurisdiction over Princes and others under New York's long-arm statute; (8) modified due process standard appro- priate for mass torts would not be applied to question of p

rts would not be applied to question of personal juris- diction; (9) allegations were insufficient to estab- lish general personal jurisdiction over Princes; (10) survivors failed to establish personal jurisdiction over founder of Saudi Arabian company; (11) limited discovery would be permitted with reg

nction exception to torts exception of FSIA; 7 a, survivors failed to make prima facie showing necessary to establish person- al jurisdiction over Princes and others under New York’s long-arm statute; (8 nai modified due process standard appro- priate for mass torts would not be applied to question o

) 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

e fully submitted. Second, the article and *551 its translation have not been authenticated. More pointedly, however, it simply does not say that the Princes were put on notice regarding specific charities and that they continued to contribute to those charities with the intent that their donations would a

ey are sued for actions undertaken within the scope of their official capacities”). Thus, Plaintiffs must also show that an FSIA exception applies to Princes Salman and Naif. Virtual Countries, 300 F.3d at 241. C. Application of FSIA Torts Exception WESTLAW Plaintiffs claim any immunity enjoyed by SHC, Pr

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