Epstein Secrets

seq. 10. International Law <-10.33 Director of Saudi Arabia’s Depart- ment of General Intelligence (DGI) was im

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

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 -

very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts crucial to an immuni- ty determination.”)). The Second Circuit has instructed “that generally a plaintiff may be allowed limited discovery with re- spect to the jurisdictional issue; but until [plaintiff] has sho

nly NCB’s contacts with the United States and not Saudi Arabia’s relationship to NCB. The Supreme Court and Secon

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

e product of [its] participation in al Qaida’s jihadist campaign.” (Federal Compl. Jf 182, 189.) *549 2. Prince Salman’ Prince Salman is a member of the Kingdom of Saudi Arabia’s Council of Ministers, the governor of the province of Riyadh, and the President of Defendant SHC. (Prince Salman Mem. in Sup. Mot. to Dismiss

yal family have assets and do business in the United States. (Ashton Compl. § 296.) 3. Prince Naif® Prince Naif has been the Minister of Interior of the Kingdom of Saudi Arabia since 1975. (Ashton Compl. J 286; Federal Compl. § 433; Prince Naif Mem. in Supp. Mot. to Dismiss at 1, 5.) According to Plaintiffs, the Minister of

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

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

is only 1.4% in Canada, 2% in China, 3.9% in Russia, 2.6% in the UK, 1.3% in Germany and I% in Japan. In the world's top 15 military spenders, only Saudi Arabia's 8.7% of GDP is higher than in the US and the US military spending is larger than the combined military budgets of the other 14 countries with a popu

ation. He argued more cases before the United States Supreme Court than anyone else in history. He served on the United States Court of Appeals for the Second Circuit after being appointed by President John F. Kennedy and then served aS the Solicitor General after being appointed by President Lyndon Johnson in 196

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

11, 2001., 2012 WL 257568 (2012) On January 18, 2005, Judge Casey issued his decision in Terrorist Attacks I, dismissing claims against, inter alia, the Kingdom of Saudi Arabia and several Saudi Princes on sovereign immunity and personal jurisdiction grounds. Judge Casey held that the FSIA protected the Princes from claims a

favor.” Amaker v. N.Y. State Dep’t of *63 Corr. Servs., 435 F. App’x 52, 54 (2d Cir. 2011) (quoting Chambers v. Time Warner, Inc., 282 F.3d 147, 152 (2d Cir. 2002)). WESTLAW HOUSE_OVERSIGHT_023384 --- PAGE BREAK --- In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) Argument I. Th