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y 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- tirely on factual
ned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 11325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-d
ry 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- tirely on factual al
Page: HOUSE_OVERSIGHT_017869 →-owned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 91325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-des
Page: HOUSE_OVERSIGHT_017887 →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 it does not acc
Page: HOUSE_OVERSIGHT_017920 →lippines office, which served as a center of terrorist financing and training. (Ashton Compl. § 310; Burnett Compl. § 234; Federal Compl. §§ 135-36.) Khalifa collected and laundered money for al Qaeda through ITRO’s Phillipines office. (Ashton Compl. J 316; Burnett Compl. J 240.) Through Khalifa, TRO was a
Page: HOUSE_OVERSIGHT_017924 →Entities connected to both Friedlander and Khalifa

United States
LOCATION
Lebanon
LOCATION
al-Qaeda
ORGANIZATION
Michael Cohen
PERSON
Bill Clinton
PERSON
Supreme Court
ORGANIZATION
Riyadh
LOCATION
Houston
LOCATION
United Kingdom
LOCATION
Yemen
LOCATION
Saudi Arabia
LOCATIONthe Council of Ministers
ORGANIZATION
Osama bin Laden
PERSON
Alfredo Rodriguez
PERSON
Somalia
LOCATION
New York
LOCATION
Jeffrey Epstein
PERSON
Kenya
LOCATION
James P. Kreindler
PERSONBurnett
PERSON