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

deter- mine which of the Network's entities have a presence in Virginia and which entities transferred money to Nada and Nasred- din. 10. Mel AJ. Batterjee The Burnett Plaintiffs claim that Defen- dant Mel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 1181. On December 21, 2004,

) 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

Adel A.J. Batterjee is an associate of Osama bin Laden. Burnett Complaint 9181. On December 21, 2004, the U.S. Department of Treasury designated Mr. Batterjee as a Specially Designated Global Terrorist. See Dec. 23, 2004 Bierstein let- ter to Court; Exec. Order No. 13224. Mr. Batterjee is the chairman of Al

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

al Foundation (“BIF”) and Adel A.J. Batterjee had. See Terrorist Attacks I, 349 F.Supp.2d at 823-25 (finding Court had personal jurisdiction over Mr. Batterjee based on his designation as a global terrorist, his role with BIF, another designated terrorist, his *561 leadership of BIF’s United States operation