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e foreign defendant regarding the scope of his offi- cial responsibilities. 28 U.S.C.A. § 1602 et seq. 10. International Law C=.10.33 Director of Saudi Arabia's Depart- ment of General Intelligence (DGI) was immune from Antiterrorism Act (ATM suit by survivors of victims of Septem- EFTA00795032 768 349 F
therefore, limited jurisdictional discovery is warranted. As explained above, the PIF could qualify either as an organ or political subdivision of the Kingdom of Sa- udi Arabia. Additionally, the affidavits on which the parties ask the Court to rely have not been subjected to cross examina- tion and are rather self-serving
m of Saudi Arabia 112, at Berger Decl. Ex. 7 ("It is the position of the Ministry of Foreign Affairs that NCB is a government instru- mentality of the Kingdom of Saudi Ara- bia."). To enjoy immunity from suit under the FSIA, NCB must demonstrate that it is an agency or instrumentality, or a politi- cal subdivision
ts con- sideration of the Defendants' motions for failure to state a claim. See Part III below. Plaintiffs place great reliance on Halber- stam v. Welch, 705 F.2d 472 (D.C.Cir.1983) and Bairn v. Qitnotic Literacy Institute. & Holy Land Foundation for Relief & Devel- opment, 291 FM 1000, 1023 (7th Ci
Neom, on the Red Sea, for talks with Crown Prince Mohammed bin Salman and U.S. Secretary of State Mike Pompeo." But, these reports "were denied by Saudi Arabia's foreign minister, Prince Faisal bin Farhan Al Saud." Netanyahu, himself, "was circumspect about any clandestine travel." Asked about it, Netanyahu s
loomberg <https://www.bloomberg.com/news/articles/2020-11-23/michigan-certifies-election-results-showing- biden-victory-khv2my15?smd=premium> (11/23, Welch, 4.73M) says the vote by Michigan's Board of State Canvassers "means that only a possible Republican request for a recount stands in the way of assu
Neom, on the Red Sea, for talks with Crown Prince Mohammed bin Salman and U.S. Secretary of State Mike Pompeo." But, these reports "were denied by Saudi Arabia's foreign minister, Prince Faisal bin Farhan Al Saud." Netanyahu, himself, "was circumspect about any clandestine travel." Asked about it, Netanyahu
certification in Michigan, which "comes days after certification in Georgia, another hotly contested presidential battleground." Bloomberg (11/23, Welch, 4.73M) says the vote by Michigan's Board of State Canvassers "means that only a possible Republican request for a recount stands in the way of assu
seq. 10. International Law <-10.33 Director of Saudi Arabia’s Depart- ment of General Intelligence (DGI) was im
the foreign defendant regarding the scope of his offi- cial responsibilities. 28 U.S.C.A. § 1602 et seq. 10. International Law <-10.33 Director of Saudi Arabia’s Depart- ment of General Intelligence (DGI) was immune from Antiterrorism Act (ATA) suit by survivors of victims of Septem- HOUSE_OVERSIGHT_017832 -
Page: HOUSE_OVERSIGHT_017832 →ngdom of Saudi Arabia 12, at Berger Decl. Ex. 7 (“It is the position of the Ministry of Foreign Affairs that NCB is a government instru- mentality of the Kingdom of Saudi Ara- bia.”). To enjoy immunity from suit under the FSIA, NCB must demonstrate that it is an agency or instrumentality, or a politi- cal subdivision of the Kin
Page: HOUSE_OVERSIGHT_017854 →Entities connected to both Saudi Arabia and Welch

Jeffrey Epstein
PERSON
Barack Obama
PERSON
United States
LOCATION
Bill Clinton
PERSON
Bloomberg L.P.
ORGANIZATION
George W. Bush
PERSON
Middle East
LOCATION
Marc Rich
PERSON
Condoleezza Rice
PERSON
Donald Trump
PERSON
Riyadh
LOCATION
Yemen
LOCATION
Prince Andrew
PERSON
Malaysia
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Charles
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON