Epstein Secrets

ritable organiza- tions enjoying state support ... to Islam- ist movements or terrorist groups." The only charity he names in his statement is 799 the World Islamic League, not one of the charities to which the Princes allegedly donated. Exhibits 21-24 are excerpts from The Muslim World regarding Prince Sultan's do

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

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

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

di charitable organiza- tions enjoying state support ... to Islam- ist movements or terrorist groups.” The only charity he names in his statement is the World Islamic League, not one of the charities to which the Princes allegedly donated. Exhibits 21-24 are excerpts from The Muslim World regarding Prince Sultan’s donati

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)

and Federa/ complaints. 3 Prince Naif moves to dismiss the Ashton, Burnett, and Federa/ complaints. 4 The French Interior Minister named one charity, the World Islamic League, during his meeting. Plaintiffs claim this is another name for the Muslim World League. 5 Plaintiffs bring the Court’s attention to Mwani v. bin La