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before discov- ery and decided without an evidentiary hearing, Plaintiffs need only make a prima facie showing that personal jurisdiction ex- ists. PDK Labs, Inc. a Friedlander, 103 F.3d 1105, 1108 (2d Cir.1997); AL Trade Finance, Ina a Petra Bank, 989 F.2d 76, 79 (2c1 Cir.1993). Plaintiffs may rely en- tire
he relocated to Sudan in 1991. Ash- ton. Complaint 1 548; Burnett Complaint 1 317. For example, SBG, through two subsidiaries allegedly supported Osama bin Laden's participation in the construc- tion of the Tahaddi road and Port Sudan Airport. Ashton Complaint 111550; 552, 553; Burnett Complaint 111319-322.
e met with members of the Taliban and representa- tives of bin Laden and agreed to not extra- dite bin Laden or close terrorist camps in exchange for bin Laden’s protection of the II, 292 F.Supp.2d at 16. This Court has re- viewed these affidavits and agrees with Judge Robertson’s assessment. For example, one
Page: HOUSE_OVERSIGHT_017850 →t before discov- ery and decided without an evidentiary hearing, Plaintiffs need only make a prima facie showing that personal jurisdiction ex- ists. PDK Labs, Inc. v. Friedlander, 103 F.8d 1105, 1108 @d Cir.1997); AZ. Trade Finance, Inc. v. Petra Bank, 989 F.2d 76, 79 (2d Cir.1993). Plaintiffs may rely en- tirel
Page: HOUSE_OVERSIGHT_017869 →Rule WESTLAW of Civil Procedure 12(b)(2), Plaintiffs must make a prima facie showing that personal jurisdiction exists over each moving Defendant. PDK Labs, Inc. v. Friedlander, 103 F.3d 1105, 1108 (Qd Cir.1997). The Court reviews the complaints and affidavits in a light most favorable to Plaintiffs, id., but
Page: HOUSE_OVERSIGHT_017920 →haracterized [him] as having ‘directed organizations that have provided financial and logistical support to al-Qa-ida, [he] is the logistics chief of bin Laden’s organization and fought on bin Laden’s side in WESTLAW Afghanistan.’ ” (Ashton Compl. J¥ 304, 312, 523-24; Burnett Compl. J 236, 255, 271; Federal
Page: HOUSE_OVERSIGHT_017923 →Entities connected to both PDK Labs, Inc. and Osama bin Laden

Bill Clinton
PERSON
United States
LOCATION
al-Qaeda
ORGANIZATION
Lebanon
LOCATION
Yemen
LOCATION
Sudan
LOCATION
Michael Cohen
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Riyadh
LOCATION
Philadelphia
LOCATION
Supreme Court
ORGANIZATION
Barry Diller
PERSON
Somalia
LOCATION
Kenya
LOCATION
Houston
LOCATION
U.S. Treasury
ORGANIZATION
Georgina Chapman
PERSON
Ethiopia
LOCATION