Epstein Secrets

pation in al Qaida's jihadist campaign." Id. 11425. Specifical- ly, the Kingdom allegedly maintained and controlled several of the charities within al Qaeda's infrastructure. Id. 11399. The Federal Plaintiffs claim Saudi Arabia knew the threat that these charities posed par- ticularly to the United State

e Sultan and Prince Turki both move to dismiss the complaints against them in Ashton v. Al Qaeda Islamic Army. 02 Civ. 6977 (S.D.N.Y.); Barrera v. AI Qaeda Islamic Army, 03 Civ. 7036 (S.D.N.Y.); Burnett v. AI Baraka Inv. & Dev. Corp., 02 Civ. 1616 (D.D.C.); Burnett v. Al Baraka hrv. & Dev. § 2331 et

began a company in the 1940s that now supplies automobiles, soft drinks, construction equipment, and other related to any alleged conspiracy or to al Gaeda's activities. EFTA00795081 IN RE TERRORIST ATTACKS ON SEPTEMBER 11, 2001 Cut as 349 F.Supp-20 765 (S.D.N.Y. 2003) goods and services to large port

including charities, banks, front organizations, terrorist organizations, and financiers who provided financial, lo- gistical, and other support to al Qaeda.1 See, e.g., Ashton Complaint 1 5; Burnett Complaint "Introduction"; Federal Com- plaint 11142-66. The complaints assert subject matter jurisdiction

6. The various complaints make substan- tially similar accusations against Prince Sultan. See Consolidated Jeffress Decl. 16. IIRO is allegedly an al Oaeda front that has been tied to the 1993 World Trade Center attack and the 1998 embassy bombings. See, e.g., Burnett Complaint 711 156, 240, 242. 17.

t mem- bers of the Spanish al Qaeda cell used Arab Bank to make wire transfers. Bur- nett Complaint 1 138 (alleging Arab Bank is "used regularly by al Qaecla's Spanish cell for transfers of cash to members of al Qaeda operating in Germany, Pakistan, Af- ghanistan, Lebanon, Yemen, Bosnia, and elsewhere");

ugh their contributions to, and support of, Islamic charities that they knew or should have known were supporting ter- rorist organizations such as al Qaeda.n Additionally, Plaintiffs allege Prince Turki aided and abetted the terrorists by at- tempting to deflect their activities away from Saudi Arabia and

Arab Jamahiriya, 290 F.Supp.2d 54 (D.D.C.2003)—Plaintiffs submit that the moving Defendants knew that the primary target of Osama bin Laden's and al Qae- da's campaign of terror was the United States and that by providing assistance to these terrorists, who Plaintiffs claim were Defendants' co-conspirato

149 F.3d at 123; Boim II, 291 F.3d at 1023; Bohn III, 340 F.Supp2d at 906. Even move and launder money. 12(e) Statement I. Plaintiffs allege that al Oaeda has pervert- ed the Zakat and Hararm principles in Islam- ic banking to collect and distribute money to individuals and cells throughout the world.

0 (hereinafter "Supp. Al-Wohai- bi Aff."). a. Status of the PIF In Filler v. Hanvit Bank, a case with facts very similar to those presented here, the Second Circuit reiterated Dole Food's requirement of direct ownership for instru- mentality status. Two defendants were commercial banks majority-owned by the Ko

to groups designated by the United States as foreign terrorist organizations, a figure that reflects the persistent threat posed by outfits such as al-Qaida and Hezbollah." VOA adds, "There are currently 68 individual groups on the U.S. State Department's list of foreign terrorist organizations, the vast

e Madoffs firm and had been a party to the lower court cases — urged the court to reject a certiorari petition asking it to take up the case, saying the Second Circuit got it right, and arguments that the decision contradicts other high court' rulings. Two Men Plead Guilty In Uber, Lynda.com Hacks. The New York (N

he orders dismissing those defendants should be vacated so that the district court can apply current law to defendants’ motions. Standard of Review The Second Circuit “review[s] de novo a district court’s dismissal of a complaint pursuant to Rule 12(b)(6), construing the complaint liberally, accepting all factual a

ion; BGC Partners, Inc., a publicly-traded corporation, indirectly owns more than 10% of it. 11-3490, 11-3494, 11-3495, 11-3511 (Federal Ins. Co. v. al Qaida): Appellants Federal Insurance Company, Pacific Indemnity Company, Chubb Custom Insurance Company, Chubb Indemnity Insurance Company, Chubb Insuranc

aeessreeenseeeseseaess 24 The Role of Ostensible Charities in al-Qaeda’s Growth and Development 2.00... cccceescceesseeeeteeceeeseeeeeteeeeteneeee 28 Al-Qaeda’s Collaborators in the Financial Industry cee eecsssssseesseessseeesneeceseceseeesneeenseceseeesneeseseceseeeaeeeeneeeateeeatersneess 42 Al-Qaeda’s Add

t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe

m- HOUSE_OVERSIGHT_017830 --- PAGE BREAK --- 766 ber 11, 2001 terrorist attacks, as well as insurance carriers, brought actions against al Qaeda, al Qaeda’s members and associ- ates, alleged state sponsors of terrorism, and individuals and entities who allegedly provided support to Al Qaeda, asserting cau

m Act (ATA) complaint by survivors of victims of September 11, 2001 attacks, alleging that Saudi Princes con- tributed to charities that supported al Qaeda, and that al Qaeda repeatedly and publicly targeted United States, failed to allege causal connection sufficient to satis- fy New York standard for c

bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi

59; see also Ashton Compl. § 452; Burnett Compl. J 398.) The Federal Plaintiffs claim that the SHC “has long acted as a fully integrated component of al Qaida’s logistical and financial support infrastructure ... [and that the attacks of September 11 were] a direct, intended and foreseeable product of [its] p

Accordingly, the only dispute regarding SHC’s status is whether it is an organ of the Kingdom. In Filler v. Hanvit Bank, 378 F.3d 213 (2d Cir.2004), the Second Circuit considered various factors to determine whether an entity could be considered an organ of a foreign sovereign. Jd. at 217. The factors include: (1)