Epstein Secrets

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

nal discovery regarding potentially sovereign alter ego co-defendant without further im- pinging that defendant’s immunity) (quot- ing Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (th Cir.1992) (“At the very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts c

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

l discovery regarding potentially sovereign alter ego co-defendant without further im- pinging that defendant's immunity) (quot- ing Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (5th Cir.1992) ("At the very least, discovery should be ordered 783 circumspectly and only to verify allega- tions of specific

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

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

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)

Court is hesitant to do unnecessarily. See First City, Texas—Houston, N.A. v. Rafidain Bank, 150 F.3d 172, 176 (2d Cir.1998); see also Arriba Ltd. v. Petroleos Mexicanos, 962 F.2d 528, 534 (Sth Cir.1992) (recommending that “discovery should be ordered circumspectly and only to verify allegations of specific facts cruc